RICHMOND DISTRICT OFFICEPresents

An Overview of Compliance

CONTENTS

-OFCCP Overview

- Compliance Evaluations

-Affirmative Action

-Recruiting Source/Contractor Linkage

-Complaints

PROTECT WORKERS

PROMOTE DIVERSITY

ENFORCE THE LAW

OFCCP’s Mission

OFCCP

Ensures that federal contractors comply with the laws and regulations regarding non-discrimination and affirmative action.

OFCCP

- Executive Order 11246

- Section 503 of the Rehabilitation Act

- Vietnam Era Veterans’ Readjustment Assistance Act

How OFCCP WorksConducts Supply & Service Evaluations:• Full Compliance Review• Pre-award Review• Off-site Review of records• Focus Review• Compliance Check

Conducts Construction Evaluations

How OFCCP WorksAn analysis of affirmative action for

- women,- minorities,- veterans, and- individuals with disabilities

is completed for each Supply & Service evaluation, regardless of review type.

How OFCCP WorksAn analysis of affirmative action for

- women,- minorities,- veterans, and- individuals with disabilities

is completed for each Construction Evaluationfor which the contractor has direct federalcontracts.

How OFCCP Works

Conducts Complaint Investigations

Conducts Compliance AssistanceWorkshops

REGULATIONSThe implementing regulations are located in, The Code of Federal RegulationsTitle 41: Public Contracts and Property

Management ____________________________________

Chapter 60: Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor

REGULATIONS60-2 Affirmative Action Programs

(for women & minorities)

60-250 & 60-300 Affirmative Action for Veterans

60-741 Affirmative Action for Individuals with Disabilities

AA FOR MINORITIES AND FEMALES

Placement goals serve as objectives which are reasonably attainable byapplying every good faith effort.

Placement Goals

- Are not rigid, inflexible quotas

- Neither a ceiling or a floor

- Not set-asides

- May not supersede merit selection principles

Placement Goals

Job GroupFemales

Employed %

Female Availability

%

Establish Goals? Yes/No

If Yes, Goal for Females

Professionals 0.0% 49.7% Yes 49.70%

Admin Support 45.4% 86.9% Yes 86.90%

Placement Goals

If a goal is not met our evaluation considers:Hires, promotions, applicants,

And often most importantly, the listing of job vacancies with targeted community and recruitment organizations.

Outreach For Individuals with Disabilities

The contractor should establish meaningful contacts with appropriate social service agencies/organizations for individuals with disabilities for advice and the referral of potential employees.

Accessing Good Faith Effort

In determining if a contractor establishedmeaningful contacts, we assess itscommunications both to and fromappropriate community organizations during the period under evaluation.

In many instances we contact the community organizations for verification.

Lack of Appropriate Outreach

Failure to take affirmative action, as a result of not seeking referrals from community

organizations would be a violation.

That violation would require resolution and monitoring by OFCCP.

Lack of Appropriate Outreach

Resolution would be obtained through alegally binding agreement, which specifies the steps the contractor will take in modifying its recruitment efforts to come intocompliance.

Lack of Appropriate Outreach

One of the primary steps in the process of resolution is linking the contractor to community and recruitment organizations who might provide qualified applicants from the group for which affirmative action isnecessary.

OFCCP calls this process Linkage.

LINKAGE

The primary goal of linkage is to increase employment opportunities for minorities, women, veterans, and individuals with disabilities.

EXAMPLE OF SUCCESSFUL LINKAGE

The Workforce Awareness Group is apartnership of federal contractors, andmultiple federal, state, and local agencies who work on behalf of covered veterans.

Workforce Awareness Group

The group is a partnership between

- The Richmond District Office- Office of Apprenticeship Training- US Department of Labor – VETS- Virginia Employment Commission- Virginia Rehabilitative Services- US Department of Veteran Affairs- Federal Contractors

Workforce Awareness Group

WAG has successfully assisted veterans and disabled veterans in employment through participation in Veteran Seminars, Job Fairs, and Stand Downs. WAG has partnered with military basesto serve Veterans and Veterans withDisabilities.

COMPLAINTS

Individuals who are protected by OFCCP mayfile a complaint if they believe they beendiscriminated against by a federal contractoror subcontractor.

COMPLAINTS

OFCCP investigates individual complaints filed under disability or veteran status.

Individual complaints based on race or genderare usually passed on to EEOC, as a result ofa Memorandum of Understanding.

COMPLAINTS

Complaints involving groups of people are generally investigated by OFCCP, regardless of whether the protected group members are minorities, females, veterans or individuals with disabilities.

COMPLAINTS

http://www.dol.gov/ofccp/index.htm

Click ‘file a discrimination complaint”

CUSTOMER SERVICE

For answers to other questions you call

OFCCP Help Desk (202) 693-0101

Richmond District Office (804) 888-6714

CUSTOMER SERVICE

USDOL National Call Center

1-866-4-USA-DOL

(1-866-487-2365)

Questions?

Office of Federal Contract Compliance Programs