Another Financial Violation That Could Have Been Avoided

I always stress UNIFORMITY AND CONSISTENCY with policies and procedures. I am not an alarmist, I know how the US DOL OFCCP works.  The beauty of working with a former Compliance Officers/Investigators is our years of knowing what can cause issues.  See below: On April 30, 2015, Comcast entered into a Conciliation Agreement with OFCCP to address the notice of violation issued on March 22, 2011.  OFCCP determined that between March 2006 and September 2007 that Comcast in Everett, Washin...
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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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OFCCP Revised Scheduling Letter and Itemized Listing Approved by OMB

On September 30, 2014, the Office of Management and Budget (OMB) approved OFCCP’s revised scheduling letter and itemized listing.  The approval expires on March 31, 2016. As a result, OFCCP is no longer using the previous versions of these documents to schedule compliance evaluations. OFCCP will not schedule supply and service compliance evaluations from October 1 through October 15, 2014. Contractors should use this period to review and become acquainted with the new letter and itemized ...
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What is the Value of an Effective Affirmative Action Plan?

There is much value from a well developed and maintained Affirmative Action Plan. The Plan is a well organized depiction of the Company’s workforce. It is an easy way to assess and appraise job functions. Since an AAP forces HR personnel to examine all Job Titles making sure they are placed in appropriate Job Groupings which allow for easy job postings. Affirmative Action is a great hiring tool for it allows for the best qualified candidate to show up. The term casting the widest net possibl...
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Hiring Procedures: 7 Tips That Will Help Your Organization Ensure Affirmative Action Compliance

For most companies, hiring procedures cause issues, not only big ones with the US DOL, but also internal problems. First, most financial violations that the US Department of Labor Office of Federal Contract Compliance Programs (OFCCP) finds are in hiring. How does a company avoid these problems? The best way is training and checks to ensure everyone knows to be consistent with policies and procedures. But let’s back up a bit. Make sure that your company Policies and Procedures are updated, and...
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