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.
Can the Self-Identification forms for Protected Veterans and the Self-Identification forms for Disability all be filed together? I keep a notebook on each form by alphabetical order. But would like to make it one book for all. The all expire at same time. Can I do that? It would be nice to file new hires or terms into one book rather than 3 separate ones. They are not kept with the Personnel files.
The regulations under VEVRAA and Section 503 of the Rehabilitation Act do not state anything specific regarding where to house self-identification forms. However, any forms that would contain medical information typically is stored in file cabinet under lock and key. Both of these forms can be stored together but should be kept apart from the regular employee file and in a place that is secure and only accessible to persons needing this information for the preparation of required reporting (e.g....
I realize the US Virgin Islands are US territories… do they fall under VEVRAA?
The answer is "no," and the citation is 41 CFR Section 60-300-5(a)(5). “The provisions of paragraphs 2 and 3 of this clause do not apply to the listing of employment openings which occur and are filled outside of the 50 states, the District of Columbia, the Commonwealth of Puerto Rico, Guam, the Virgin Islands, American Samoa, the Commonwealth of the Northern Mariana Islands, Wake Island, and the Trust Territories of the Pacific Islands.”
Our marketing team is receiving more questions around digital accessibility. Do you have any consultants or recommendations on a company we could use to provide training?
There are many organizations that not provide a review of websites for accessibility as well as perform remediation. The Job Accommodation Network and EARN have information regarding website accessibility. Organizations such as Hire Potential, The Sierra Group, and Audio Eye are just a few organizations who perform this type of service and employ individuals with disabilities to assist in conducting the accessibility review. Biddle Consulting Group performs training on accommodations, compliance with ADA/Section 503, and inclusive practices for individuals with...
For EEO-1 reporting, we have typically included remote employees in their manager’s location. However, with more employees now working remotely, we are unclear on how this “roll-up” should be performed. For example, if an entire department’s hierarchy works from home, is it reasonable to simply include all of them in headquarters?
Remote employees would roll up to the location of their reporting manager. If the reporting manager is report, you can follow the line of reporting up to the next tier until it reaches a physical work location in which the remote employees can be rolled into. For many organizations with a remote managers, this would mean that they would roll up to the headquarters location.
Are we required to have recruiters enter their pre-screen/interview notes in the ATS or is this just considered a best practice?
The regulations under EO 11246 do not indicate that pre-screening/interview notes need to be maintained within the ATS. However, the OFCCP does expect contractors to maintain interview notes in some format for the required record retention period which is typically two years depending on the size of the company and amount of the federal contract. The OFCCP has posted FAQs regarding the internet applicant at the following site: https://www.dol.gov/agencies/ofccp/faqs/internet-applicants
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