How to Stay OFCCP Compliant in Your Promotion Policy and Hiring Procedure

  To stay OFCCP compliant, be very precise in outlining your company’s Promotion Policy and Hiring Procedure.  A case was handed over to me to investigate when it was stalled by the original Compliance Officer. An Impact Ratio Analysis could not be conducted.  The original CO saw that females were not upper level Job Groups.  The assumption was potential discrimination for females. The company did not have a set procedure to handle promotions.  When a position is posted internally...
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Be Careful with Job Descriptions: Tales from a Former Compliance Officer

  Be careful with job descriptions.  During an onsite audit  in South GA, we were investigating potential description in Job Group 2 (Professionals) and Job Group 3 (Technicians).  The company used the basic job qualifications for all professionals.  They did not distinguish between the different requirements for different Accountants, entry level with limited experience, significant experience with more education, and CPAs.  All of these were included in the same pool.  The HR perso...
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