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RICHMOND DISTRICT OFFICE Presents An Overview of Compliance
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RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

Dec 15, 2015

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Page 1: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

RICHMOND DISTRICT OFFICEPresents

An Overview of Compliance

Page 2: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

CONTENTS

-OFCCP Overview

- Compliance Evaluations

-Affirmative Action

-Recruiting Source/Contractor Linkage

-Complaints

Page 3: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

PROTECT WORKERS

PROMOTE DIVERSITY

ENFORCE THE LAW

OFCCP’s Mission

Page 4: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

OFCCP

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

Page 5: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

OFCCP

- Executive Order 11246

- Section 503 of the Rehabilitation Act

- Vietnam Era Veterans’ Readjustment Assistance Act

Page 6: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

How OFCCP Works

Conducts Supply & Service Evaluations:

• Full Compliance Review

• Pre-award Review

• Off-site Review of records

• Focus Review

• Compliance Check

Conducts Construction Evaluations

Page 7: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

How OFCCP Works

An analysis of affirmative action for

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

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

Page 8: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

How OFCCP Works

An analysis of affirmative action for

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

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

Page 9: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

How OFCCP Works

Conducts Complaint

Investigations

Conducts Compliance Assistance

Workshops

Page 10: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

REGULATIONS

The implementing regulations are located in, The Code of Federal Regulations

Title 41: Public Contracts and Property Management ____________________________________

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

Page 11: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

REGULATIONS

60-2 Affirmative Action Programs (for women & minorities)

60-250 & 60-300 Affirmative Action for Veterans

60-741 Affirmative Action for Individuals with Disabilities

Page 12: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

AA FOR MINORITIES AND FEMALES

Placement goals serve as objectives

which are reasonably attainable by

applying every good faith effort.

Page 13: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

Placement Goals

- Are not rigid, inflexible quotas

- Neither a ceiling or a floor

- Not set-asides

- May not supersede merit selection principles

Page 14: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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%

Page 15: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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.

Page 16: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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.

Page 17: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

Accessing Good Faith Effort

In determining if a contractor established

meaningful contacts, we assess its

communications both to and from

appropriate community organizations during the period under evaluation.

In many instances we contact the community

organizations for verification.

Page 18: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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.

Page 19: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

Lack of Appropriate Outreach

Resolution would be obtained through a

legally binding agreement, which specifies

the steps the contractor will take in modifying

its recruitment efforts to come into

compliance.

Page 20: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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 is

necessary.

OFCCP calls this process Linkage.

Page 21: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

LINKAGE

The primary goal of linkage is to

increase employment opportunities for

minorities, women, veterans, and

individuals with disabilities.

Page 22: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

EXAMPLE OF SUCCESSFUL LINKAGE

The Workforce Awareness Group is a

partnership of federal contractors, and

multiple federal, state, and local

agencies who work on behalf of covered

veterans.

Page 23: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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

Page 24: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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 bases

to serve Veterans and Veterans with

Disabilities.

Page 25: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

COMPLAINTS

Individuals who are protected by OFCCP may

file a complaint if they believe they been

discriminated against by a federal contractor

or subcontractor.

Page 26: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

COMPLAINTS

OFCCP investigates individual complaints

filed under disability or veteran status.

Individual complaints based on race or gender

are usually passed on to EEOC, as a result of

a Memorandum of Understanding.

Page 27: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

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.

Page 28: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

COMPLAINTS

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

Click ‘file a discrimination complaint”

Page 29: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

CUSTOMER SERVICE

For answers to other questions you call

OFCCP Help Desk

(202) 693-0101

Richmond District Office

(804) 888-6714

Page 30: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

CUSTOMER SERVICE

USDOL National Call Center

1-866-4-USA-DOL

(1-866-487-2365)

Page 31: RICHMOND DISTRICT OFFICE Presents An Overview of Compliance.

Questions?

Office of Federal Contract Compliance Programs