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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News Release – US Labor Department secures nearly $2M in back wages, benefits for nearly 150 workers at federally-funded solar energy project in Nevada

News Release   US Labor Department secures nearly $2M in back wages, benefits for nearly 150 workers at federally-funded solar energy project in Nevada LAS VEGAS — The U.S. Department of Labor has recovered $1,914,681.50 in back wages and fringe benefits for 147 workers at Proimtu Mmi-Nv LLC, a Henderson-based subcontractor providing construction services at the federally funded Crescent Dunes Solar Energy Project in Tonopah. This project, which received a $737 million loan guarante...
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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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5 Tips on Creating a Legally Sound HR Policy

Human Resources policies and procedures establish a framework and set standards that guide how each employee should conduct themselves. This includes how a job is performed, how employees make decisions, interact with one another and manage the business operations of your company. A well-written policy leaves nothing to the imagination and lets both the employee and employer know where they stand within the company. These policies are organized, consistent and legally sound.  HR staff member...
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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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5 Reasons Why Your Affirmative Action Compliance Efforts Should Be Outsourced:

We take pride in knowing that even the smallest employers are going to save money by having their plan done by First Advantage Consulting Firm, LLC. Small and Large companies will no longer have the worry and anxiety of not knowing for sure if they are in compliance or not by providing the best possible plan in accordance to regulatory requirements. We eliminate that worry so you can address other issues. Lager employers can save potentially larger amounts of money if they have multiple plans...
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