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Affirmative Action Compliance Review Checklist

Checklist
Affirmative Action

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The Office of Federal Contract Compliance Procedures (OFCCP) has expressed concerns that many federal contractors are not fulfilling their legal duty to develop and maintain Affirmative Action plans and update them on an annual basis so now is a great time to evaluate your Affirmative Action Program. This basic checklist is designed to help you review your current practices and prepare for a potential OFCCP compliance review.

☐ Check to see if your company is listed on one of the Corporate Scheduling Announcement Letter (CSAL) notifications.

☐ Make sure you have a current (and compliant) Affirmative Action Program in place.

☐ Spend time reviewing your data for accuracy – especially your applicant flow.

☐ Review your process for soliciting and tracking self-identification information for women, minorities, individuals with disabilities and protected veterans.

☐ If you accept online applications, double-check that your website clearly states the manner in which a job seeker can request an accommodation or alternative application.

☐ Verify that all your employment openings are listed with the local state job service. There are a few exceptions: executive and senior management, positions filled internally and positions lasting 3 days or less do not need to be listed.

☐ Confirm your EEO/AA tagline is listed in all job postings.

☐ Review your job descriptions to ensure basic qualifications are:

  • Objective (e.g., a bachelor’s degree in accounting, rather than a technical degree from a good school);
  • Relevant to performance of the particular position; and include
  • Non-comparative features of a job seeker (e.g., three years experience in a particular position, rather than a comparative requirement such as being one of the top five among the candidates in years of experience).

☐ Evaluate and track your outreach & good faith efforts so that you are reaching out to community partners who can help refer qualified individuals for placement goals, including individuals with disabilities and veterans.

☐ Offer training for key internal stakeholders to share affirmative action obligations and insight on how to recruit and retain individuals with disabilities and veterans.

☐ Review your disability and religious accommodation policies/processes to confirm you have a standard process in place that includes interactive dialogue and tracks approvals and denials.

☐ Review your compensation policies and ensure adherence to those policies when making compensation related decisions.

☐ Verify you are completing your contractor compliance certification in the System for Award Management (https://sam.gov/content/home). This annual requirement is typically completed by your internal team that manages federal contracts.

Need help with your Affirmative Action program?  MRA’s Affirmative Action experts are available to assist you!
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