Federal Contractors and Federal Subcontractors – Part 2

November 6, 2013

This is the second segment of a two-part article focusing on the responsibilities of federal contractors and federal subcontractors. You can read Part One of the article here.

In this two-part article, EctoHR identifies “14 Common Problem Areas for Federal Contractors” that should be avoided to prevent the loss of a valuable government contract. Each article focuses on seven (7) different issues that a company can address to avoid a negative compliance review.

Part Two of the article highlights the last seven of 14 Problem Areas:

8. Lack of an adequate EEO/Sexual Harassment Program. Make it known that you have zero tolerance of harassment of any kind by maintaining an ongoing program that is well-known to employees.

9. Failure to Seek Technical Assistance from OFCCP. Asking for technical assistance will NOT trigger an audit or call attention to you as a contractor, so don’t fear going to the OFCCP directly for help, when necessary. EctoHR’s experience does indicate, however, that companies must be persistent to get adequate help.

10. Basic Affirmative Action Program Failures. Failure to establish goals, failure to update annually, and failure to maintain a basic AAP are all products of creating an AAP only after being scheduled for a review.

11. Falsifying Records or Maintaining Two Sets of Books. – Failure to provide the OFCCP with full and honest access to appropriate records is a breach of federal contract obligations. These violations are an obvious basis for enforcement.

12. No External Outreach and Positive Recruitment efforts. When you are in contact with recruitment sources, follow up with them and make sure to document referrals and feedback on applicant disposition. When using head hunters or executive search firms, remember that you are still responsible for them following your EEO/AA process!

13. No Mandatory Job Listings. Contractors must list jobs with the state workforce agency job bank. In Michigan, that is the Michigan Talent Bank, and any Michigan Works! Service center may also assist you in your efforts.

14. Lack of Reasonable Accommodations. Contractors should offer a self-identification form after hire so any needed accommodations can be determined and arranged. Existing facilities should be accessible (including parking spaces, ramps, and restrooms). Some other accommodations may be: restructuring jobs, modifying work schedules, acquiring or modifying equipment or using qualified readers/interpreters. Have procedures in place to address accommodations and document each request and its outcome.

To prevent “common problems” at your company, EctoHR provides OFCCP compliance audits to provide a clear path towards compliance and success. Contact one of our HR professionals at hr@ectohr.com or 810.534.0170.

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