OFCCP Leaves No Stone Unturned with Detailed Applicant Documentation Requests

Recent desk audits conducted by the Office of Federal Contract Compliance Programs (OFCCP) include broad follow up requests to provide extensive detail regarding the applicant selection process.

 

Following is an example of one follow up request for one position:

"All documentation (including any hand written notes and or emails)" regarding:

• who made determinations during the selection process (i.e. who made the determination to phone screen);
• interview decisions (i.e. who to forward, who would receive an offer);
• applicant decisions (i.e. not to be considered, to be considered for other positions, to withdraw from the selection process)

"All documentation (including any hand written notes and or emails)" taken during:

• screening
• interviews

"All documentation (including any hand written notes and or emails)" to show that [specified applicants]:

• did not want to be considered;
• did not meet the salary requirements;
• were not a good fit;
• were overqualified;
• did not meet minimum qualifications;
• refused work hours; and/or
• were unable to be contacted.

In anticipation of responding to a similar request, it is important to keep the following objectives in mind:

• Use control measures to ensure all records of selection activity and related documentation are objective and centrally contained; with no extraneous e-mails or personal notes;
• Use position requisition numbers to clearly identify applicants related to each position;
• Follow a consistent process* that includes disposition codes to manage the size and accuracy of applicant flow;
• Use applicant disposition codes that are related to the stated position qualifications;
• After a position is filled, review all applicant records for the position to ensure a disposition code as been assigned.

THOMAS HOUSTON associates, inc. can assist you in meeting the challenges that will arise as a result of the upcoming OFCCP's regulatory efforts. We offer pro-active and proven compliance tools and methods.

*Click Here to request a copy of our "Recommended Applicant Process Flow Chart"

For information on the Affirmative Action Program services offered by THOMAS HOUSTON associates, inc., please call (800) 330-9000 or click here to schedule a convenient time to receive a call from a member of our Sales Team.

This information is intended to be educational and should not be considered legal advice on any specific matter.