December 1, 2014

CONTRACTOR FEEDBACK ON 503/VEVRAA GOOD FAITH EFFORTS – ACCOUNTABILITY IS KEY

Recent contractor feedback related to Good Faith Efforts (GFE) toward individuals with disabilities and veterans suggests that the process of engaging in, tracking, and evaluating such efforts varies depending on the size of the contractor and/or its establishments. Smaller contractors and smaller establishments are finding that manual tracking of GFE via email archives and/or excel logs adequately meets their record-keeping needs. On the other hand, many larger contractors are taking advantage of more advanced and automated data warehousing systems or third-party service providers to not only maintain records, but to also produce analytics used to evaluate the process.  Regardless of their size, contractors seem to agree that establishing and sustaining personal and professional relationships with local veteran- and disabled-focused employment services and advocacy organizations greatly contributes to overall program effectiveness.

So how do these relationships work? It’s as easy as picking up the phone to register for a job fair or scheduling an office visit, many contractors agreed. The reality is that state and local community service organizations have just as much of an incentive to work with contractors as contractors have to work with them. Once connections are made, contractors can send out job blasts with their EEO tagline and immediately request disabled and veteran employee referrals.

One smaller contractor reported asking recruiters/generalists to manually folderize and archive all emails related to outreach efforts. For each AAP, the contractor designates one person as responsible for monitoring calls and referrals from their agency network and another as responsible for overseeing global efforts across all locations. Larger contractors often have more resources at their fingertips and can afford to assemble full Diversity and Inclusion teams to centralize and disseminate global outreach and recruitment strategies. From there, talent acquisition specialists and HR business partners and managers are trained on the regulations and tasked with targeting specific protected groups and/or job categories. Many larger contractors shared that one of their primary challenges is ensuring consistency and standardization of practices across multiple locations.

Contractors that track outcomes of candidate referral sources through their applicant tracking systems are cautioned to ensure source codes are accurate and up to date. Unsurprisingly, many contractors note the difficulty in guaranteeing valid responses when it comes to referral sources. For example, when prompted to provide referral source, “the majority of candidates select the ‘company website option’ when another option would have been more fitting,” one contractor expressed with frustration.

Third-party outreach and recruitment service providers undertake the contractor’s burden of both disseminating outreach and retaining records. For example, RECSOLU provides recruiting management software solutions which automate the candidate search and screening process and include built-in analytic tools for process evaluation. Additionally, DirectEmployers, in an effort to aid federal contractors in their EEO compliance initiatives, offers tools that link to contractor applicant tracking systems to pull and deliver job announcements and postings to the National Labor Exchange, appropriate Employment Service Delivery System (ESDS) and partner employment agencies. Keep in mind that although providers may help streamline outreach and recruitment efforts, it is ultimately the contractor’s responsibility to ensure all efforts are executed and, most importantly, are effective.

Contractors – big and small – are encouraged to take a holistic approach when determining the effectiveness of their outreach and recruitment efforts. Contractors are advised to not measure success of their programs based on 44(k) (41 CFR 60-300.44k and 60-741.44k) metrics alone. Contractors who not only establish connections with local service organizations, but go above and beyond by training their network on how they can assist the contractor with increasing the flow of disabled and veteran talent into their organizations benefit the most.  One contractor offered the suggestion to “Look at outside recognition of efforts, too; did you get invitations for speaking and training engagements?” Explaining to agency partners how they may assist you (e.g., by showing them how to “navigate the technology of your organization”) would allow you to not only check the box that “yes, I did something to evaluate outreach efforts,” but also perpetuate a long-term, professional and mutually beneficial relationship.

Best practices surrounding evaluation of outreach and recruitment efforts during an audit [for 503 and VEVRAA] focused on accountability. Third-party organizations may simplify several administrative processes related to the acquisition of qualified veteran and disabled candidates, but they should never replace regular, internal self-monitoring and evaluation protocols that confirm that good faith efforts were effective. Follow up with third-party organizations and recipients of job blast emails to ensure your notifications were received. Finally, many contractors agree that it is crucial to “document everything” and “overwhelm OFCCP with [this] documentation” during an audit.

Check back often for more tips to assist you in your 503/VEVRAA compliance endeavors.

By Jeffrey Henderson, M.P.S., Analyst, DCI Consulting Group

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INDUSTRY NEWS & LEARNING

DCI Consulting is a risk management human resources consulting firm strategically located in Washington, D.C.

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