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Circa’s Anne Holmes (on left in photo) joined Tina Williams, Deputy Director of Operations for OFCCP, to present at the 2019 NILG Conference Review in Virginia. The two speakers covered a lot of ground from effective outreach, assessment, and tracking best practices to Section 503 Focused Reviews and OFCCP’s plans for scheduling audits. You can find details on focused reviews here.

Holmes gave attendees an in-depth look at why many come up short during their outreach and selection processes. Using first-hand experience from Circa’s industry-leading OFCCP services, Holmes pointed to four major issues contractors face in hiring Individuals with Disabilities (IWD):

  • Insufficient outreach
  • Poor quality of outreach
  • Reluctance to self-identify
  • Unnecessary barriers (job requirements, site accessibility)

These are the main areas employers need to continuously evaluate. In fact, Section 503 requires contractors to assess, on an annual basis, the effectiveness of their outreach efforts. In their annual assessments, federal contractors and subcontractors must evaluate whether their outreach efforts are effective or not and document that assessment, including the criteria used to assess and their conclusion.

Williams echoed these sentiments, stressing that OFCCP continues to place its emphasis on the effectiveness of an employer’s outreach and their adjustments in strategy leading to better results. According to Williams, one reason for the focus on results is due to fewer than 5% of federal contractors reaching the 7% utilization goal for IWDs. Its a major concern that should worry employers who are obligated to show their efforts and improvement in this area.

Along with outreach, Holmes and Williams further highlighted the importance of proper applicant tracking and recordkeeping. Feedback from recent reviews show that some OFCCP offices are conducting more robust audits and asking for additional details. For example, “Outreach log: Show specific efforts to communicate with veteran and disabled organizations for each facility.”

Tracking all of your outreach as you go along is imperative to accurate, consistent data. This is especially crucial during an audit when you’ll be asked to show which organizations you’ve worked with over the past 12 months, and which ones you’ve added or subtracted based on your annual assessments (which can be reviewed over the last three-year period of time). Holmes also reiterated that properly training your recruiters – and all staff involved in your hiring and accommodation processes – is vital when it comes to understanding what is required and how to document for compliance.

Finally, Williams and Holmes emphasized numerous times that even if a federal contractor is having an agency conduct its outreach, all the obligations and requirements are the responsibility of the contractor itself! They recommended employers circle back with staffing agencies and other third-party sources to ensure they have all the appropriate documentation and additional data. The contractor should also be requesting this data routinely to remain diligent and on top of trends, because once again, the contractor is the sole entity responsible should a violation occur.




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