Audit Trend: Are You Factoring in Your Availability?
In recent months, OFCCP has exhibited an increased interest in the underlying data that are key to federal contractors’ factor availability analyses. DCI has experienced an increase in requests for information focused on census occupation codes and external availability metrics. If it has been some time since you last looked at your factor availability set-up… you are not alone! However, don’t let it linger any longer! This set-up drives your analysis and may be questioned by OFCCP. As a refresher, below are a few items to consider as you conduct your review.
Census Occupation Codes
- Revisit  Census Occupation Code pairings to ensure they are up to date and as accurate as possible. Keep in mind that there may not be a perfect match for each job title because the census occupation listing is not exhaustive. However, try to identify the closest title that best aligns with the job duties of the position in question.
Weighting and Feeder Groups
- Examine past data to identify trends in external and internal placement into each job group. Confirm feeder groups are still reasonable and active in the current year AAP roster.
- These areas should be reasonably customized for each job group. They should be free from overlap (e.g., including the U.S. and New York State as recruitment areas) and weighted based on your AAP locations. As a reminder, the regulations state that recruitment areas should not be drawn in a way that excludes minorities or women— it is best to identify them based on your typical recruitment practices.
By Yevonessa Hall, Consultant, and Macy Cheeks, HR Analyst at DCI Consulting Group