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Ask the Experts is an exclusive online forum provided by Circa. Federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity.

Hiring Contractors Full-Time

Asked By Dawn R. on May 06, 2015

When we have contractors working for us and we want to bring them on full time, how do we handle that with regards to recruiting? Do we need to open reqs, etc?

Thank you!

Answered on May 11, 2015

Bill Osterndorf - President and Founder, HR Analytical Services

Hi Dawn. This is complex question that can't be answered in a simple way in a forum like this. I'll provide several thoughts here, and then you may contact me directly at if you'd like to discuss this further. When you intend to convert contractors, and you are entirely certain that no other candidates will be considered, this is the wrong time to conduct additional recruitment. You risk the possibility of having other candidates in an applicant pool along...

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1 Answer

Survey for protected veteran status

Asked By Anonymous on May 06, 2015

Can I add another option of “I prefer to not answer” on the survey for protected veteran status?

Answered on May 06, 2015

Jacquelyn Peterson -

Including "I prefer to not answer" as an additional option is acceptable and likely helpful because it may increase the number of survey responses the employer collects on the survey for protected veteran status.

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1 Answer

Definition of Internet Applicant

Asked By Anonymous on Apr 29, 2015

I attended a recent webinar where you discussed submitting race, ethnicity, and gender data to OFCCP on Internet applicants. Can you define what that means?

Answered on Apr 29, 2015

Jacquelyn Peterson -

Under Executive Order 11246, contractors must solicit demographic information on Internet Applicants, which is defined as: 1. Individual submits expression of interest through Internet or related electronic data technologies; 2. Contractor considers individual for employment in a particular position; 3. Individual’s expression of interest indicates basic qualifications for position; and 4. Individual does not remove him/herself from consideration prior to the job offer The rule does not define the term "Internet or related electronic data technologies" because technology is constantly...

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1 Answer

Effective date of disability form

Asked By Anonymous on Apr 28, 2015

When did the OFCCP disability form become effective?

Answered on Apr 28, 2015

Jacquelyn Peterson -

The disability form was part of the Subpart C requirements in the revised Section 503 regulations. The deadline for all new requirements in Subpart C was the date on which the contractor’s pre-March 24, 2014 Affirmative Action Plan (AAP) expires. For example, a January 1, 2014 AAP date means the deadline to comply with the Subpart C requirements was January 1, 2015.

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1 Answer

Surveying for disability and veteran status

Asked By Anonymous on Apr 28, 2015

Can I survey for disability and veteran status when the candidate comes in for an interview?

Answered on Apr 28, 2015

Jacquelyn Peterson -

The revised regulations state that federal contractors and subcontractors need to survey for veteran status and disability status at the pre-offer and post-offer stages. Thus, attempting to collect this data during an in-person interview isn't the appropriate time. Consider asking the information at the same time you survey for race and gender and on the first day the new hire appears for work but before the new hire begins performing his/her duties of the job.

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1 Answer
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This forum provides information of a general nature. None of the answers or information provided is intended as legal advice or opinion relative to specific matters, facts, situations, or issues. Additional facts and information or future developments may affect the subjects addressed. You should consult with an attorney about your specific circumstance before acting on any of this information since it may not be applicable to your situation. Circa and all experts expressly disclaim all liability with respect to actions taken or not taken based on any or all of the contents of this forum.

Our Experts

Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.

Ahmed Younies

President and CEO, HR Unlimited, Inc.

Alissa Horvitz, Esq.

Member Attorney, Roffman Horvitz, PLC

Allen Hudson, PHR, SHRM-CP

CEO, HudsonMann

Beth Ronnenburg

President, Berkshire Associates

Beth Ronnenburg, SPHR, SHRM-SCP

President, Berkshire Associates

Bill Osterndorf

President and Founder, HR Analytical Services

Carey Freitag

Human Resources Manager, Circa

Carla Irwin, Esq.

President, Carla Irwin & Associates, Inc.

Craig Leen

Board Member, Circa

David Cohen

President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Lisa Kaiser, Esq.

Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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