down the rabbit hole - hudsonmann
TRANSCRIPT
Down the Rabbit HoleResponding to OFCCP’s In-depth
Audits
HELLO!I’m Allen Hudson
@HudsonMann
AGGRESSIVE“full-scale
enforcement”
FY 2013 CONCILIATION RATE
30.98%
reverseCan we
the trend?
1Beef Up Your
Initial Submission
2
3 4
Avoid CommonViolations
Other Requests Best Practicesfor Your Data
Beef upyour initial submission
ADD Theseto your initial submission
Good FaithEfforts
VETS-100a Job listingsamples
Job adsw/ eeo
statement
PurchaseOrder
Online Accessibility
language
“If you are an individual with a disability and require a reasonable accommodation to complete any part of the application process, or are limited in the ability or unable to access or use this online application process and need an alternative method for applying, you may contact phone number or
e-mail address for assistance.”
compensationdata at the ready!
have
• Employee ID• Gender• Race/Ethnicity• Job Title• Salary Grade or Band• Date of Hire• Last change in Grade• Last change in Title
• Part-time vs. Full-time• Exempt vs. Non-exempt• Contract Assignment• Base salary or rate• Hours worked (for PT)• Other paid allowances• Employee Location• Shift
Deep divethe
For each employee
CompensationPolicy
PositionDescriptions
Salary history
Performancereviews
Five daysin
Common violationsavoid
Mandatory job listings
screenshots
1st
Posting logs
2nd
3rd Parties
3rd
Good faith outreachNarrative
explanationOriginal
documentation
– Partnerships with local service organizations
– Linkage with the State Workforce Job Bank agency
– Partnership with Vocational Rehabilitation services
– Recruitment efforts at educational institutions to reach students who are covered veterans
Outreach Examples
– Job ads targeting veterans & individuals with disabilities
– Encouragement of subcontractor outreach efforts
– Veterans Administration job placement program participation
– On-the-job training opportunities
Outreach Examples
RECORDKEEPING
Expressions ofinterest
2 years’employment data
Failure to hire
Failure to hire
Adverse impact&
Failure to hire• Applicant flow log
• Copies of applications
• Job descriptions and qualifications
• Names of those involved in the interview process
• Description of hiring process
requestsother
Other Common Follow Up Requests
• Accommodation requests and dispositions
• Lists of employees who have self-identified as disabled
• Self-identification forms – pre & post offer
• Blank job application
• Employee Handbook and/or Policies
Physical & mentalWhen do you review
job requirements?
Physical exams?Do you require
Medical restrictions?Do any jobs have
EEO NoticesAre
posted conspicuously?
Review your aapHow often do you
with top management?
Best practicesfor your data
ATS
HRIS
promotions!Track
Voluntary&
involuntaryterminations
???
Thank [email protected]
creditsflickr photos
Arrows – Khairil ZhafriBooted car – quinn.anyaCow – Meneer ZjeroenDiver – cold_water_diverLaundry – codaData – puntxote
© Hudsonmann 2013
Noun project icons
Thomas le bas - BirdNick holroyd - Thumb
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Lance weisser - GaugeKen messenger - Trophy
Jon testa - BookThomas le bas - Pencil
Blake thompson - Shared interestDaniel shannon - computer