3 days before the new regulations went into effect I had the opportunity to visit the OFCCP’s Baltimore District office. The 3 OFCCP officers that I met with spoke about the fundamentals on developing Affirmative Action Programs (AAPs).
The amount of information to be in compliance can seem a bit over whelming. Below are some key focus areas that require your attention for OFCCP compliance?
Start of next AAP cycle after March 24, 2014 (Phased-in compliance)
End of your phased-in compliance AAP Year
The record keeping and documentation are vital to be in compliance with the OFCCP
Tim Orellano a speaker at the Society for Human Resource Management’s 2014 Employment Law & Legislative Conference recently said.
Compliance officers ‘chomping at the bit’ to enforce new affirmative action regulations” “This is all about your money, the OFCCP goes after all sorts of pots of gold. If you don’t have documents during an audit to substantiate why statistics are working against you, you have inferred or implied discrimination because you can’t prove otherwise.”
Some other things to keep in mind are if you are audited, expect compliance officers to demand a lengthy list of documents—including employment tests, compensation data, sometimes even “pictures of your parking spaces” for those with disabilities. Compliance officers are notorious for wanting such documents immediately.
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ABOUT THE AUTHOR:
PJ Beaulac is the principal consultant at OFCCP Consulting LLC specializing in policies and procedures. She provides guidance and hands on expertise in the field of OFCCP federal compliance as it relates to government regulations and programs. OFCCP Consulting is here to help identify and address potential issues before the OFCCP targets your company with a compliance review.
Please contact us at www.ofccpconsulting.com