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America’s Job Exchange400 Minuteman Road, Andover, MA 01810
www.americasjobexchange.com
Developing an Effective OFCCP Compliance Programfor Job Posting and Distribution
14th Annual Compliance Conference - Phoenix, AZ - November 15, 2011
Rathin Sinha
President, America’s Job Exchange
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Agenda
Compliance Regulations
Contractor Obligations
Implementation Challenges
The Case for Third Party Vendors
The AJE Advantage
Q & A
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Executive Order 11246Prohibits Federal contractors from discriminating in employment decisions
based on race, color, religion, sex or national origin.
Section 503 of the Rehabilitation Act of 1973Requires Federal contractors to take affirmative action to hire, retain and
promote individuals with disabilities.
Vietnam Era Veteran’s Readjustment Act, as amended in
conjunction with Jobs for Veterans Act (VEVRA/JVA)Requires Federal contractors to take affirmative action to hire, retain and
promote veterans.
The OFCCP mandates that companies doing business with the Federal government must
comply with the following set of regulations in their recruitment practices.
OFCCP Regulations – The Broad View
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Executive Order 11246Post job vacancy announcements to expose them to a large number of
minorities, women, and underrepresented groups.
Section 503 of the Rehabilitation Act of 1973Reach out to persons with disabilities and provide information about job
vacancy announcements.
Vietnam Era Veteran’s Readjustment Act (VEVRAA/JVA)List all employment opportunities with the appropriate employment delivery
system in the state where the job is located.
Companies must take measures to ensure that job vacancy announcements reach job
seekers who are veterans, minorities, women and persons with disabilities.
OFCCP Regulations – The Spirit of the Law
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What are the new job listing requirements under the Jobs for Veterans Act?The Jobs for Veterans Act (JVA) and the regulation implementing the JVA at 41 CFR 60-300.5 require that contractors
list job openings with the appropriate employment service delivery system.
What type of agency is considered part of the local employment service delivery system?The employment service delivery system means the public employment offices established under the Wagner-Peyser
Act, and known as the Employment Service, that provide a variety of labor exchange services including, but not limited to,
job search assistance, job referral, placement assistance, re-employment services and recruitment services.
Is there a particular way contractors must list employment openings with the appropriate
employment delivery system?A contractor may satisfy the mandatory job listing requirement by using any means that is permitted by the appropriate
employment delivery system for listing employment openings, which may include mail, facsimile (FAX), electronic
mail, or other electronic postings. The vast majority of the state workforce agency job banks accept job listings via the
Internet. Contractors may use third parties, such as private or non-profit sector job banks, Internet gateway and portal
sites, and recruiting services and directories, to assist them with the transmission of job listings to the appropriate
employment service delivery system. However, a contractor remains responsible for complying with OFCCP's job
listing requirements.
The regulations are very specific as they relate to job posting requirements for VEVRAA/JVA
OFCCP Regulations – The Letter of the Law
Source: http://www.dol.gov/ofccp/regs/compliance/faqs/jvafaqs.htm#Q11
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Post Jobs in National Job SitesPost job listings in job sites that reach large number of seekers including
minorities, women, veterans and the disabled.
Post Jobs in Niche Job SitesPost jobs in niche job sites that are specifically targeted to minorities, women,
veterans and people with disabilities.
Send Jobs to State Employment Delivery SystemsSend job listings to the public employment offices by mail, fax, email or other
electronic means, or to the state job banks.
The law obligates contractors to be accountable for a set of activities, whether performing
internally or using a third party vendor, and to be ready to show proof, if audited.
Contractor Obligations
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Major Job Sites are ExpensiveA single job posting for a specific location costs approximately $400.
Niche Job Sites are ExpensiveA single job posting costs approximately $175, and costs rise fast when
posting in multiple sites to reach different audiences.
Cost to Send Jobs to State Systems is HighState job banks are free, but manually posting to them is labor intensive as is
sending jobs to employment offices by mail, fax or email.
Administrative Costs of Maintaining Records is SignificantKeeping detailed records can create a lot of work for internal employees, as
well as maintaining consistency of content.
For most contractors performing these tasks internally and maintaining proper records is
labor intensive and incurs a significant expense.
Implementation Challenges
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Job Postings on AJE and the AJE Network of Job SitesListings that reach a million job seekers per month with a large
concentration of minorities, women, veterans and the disabled.
Job Postings to Niche Diversity Partner WebsitesListings that reach job seeker audiences in targeted communities of
minorities, women, veterans and people with disabilities.
Job Delivery to the Appropriate State Employment SystemsAutomated job delivery to State Workforce centers, Career One Stop
Centers, LVERs and DVOPs, and CBO organizations.
On-Demand Audit Reporting with Custom Report DownloadsShows record of job posting and delivery, related links and job description,
time and date stamps, and delivery confirmation.
For a fraction of this cost, Federal contractors can obtain solutions from third party vendors
such as America’s Job Exchange (AJE), a leader in recruitment compliance.
A Better Alternative
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Automated TechnologyState-of-the-art web platform, job distribution technology, data
exchange mechanism, and search methodologies.
PartnershipsLarge network of partnerships with niche job sites, community
organizations, states, associations and employment agencies.
Domain ExpertiseAs developer and operators of the America’s Job Bank program, AJE
has more than 15 years of experience in this area.
Scale EconomicsAJE serves more than 500 of the leading enterprises for compliance
solution and derives efficiency from repetitive processes.
Third party vendors such as AJE achieve efficiency through a combination of automated
technology, partnerships, domain expertise and scale economics.
Efficiency Drivers
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Traffic GenerationGet traffic to your jobs as well as to your career website through
search engine optimization (SEO) and search marketing (SEM).
Recruitment Brand DevelopmentA full suite of media products for recruitment sourcing, corporate
branding, diversity branding and advertising.
Recruitment Technology ServicesA full suite of technology services including data feed preparation,
career site development and hosting.
Audit Support and Document ManagementLive customer service and assistance in the event of an audit
including consultation, and retrieval of past documents.
Solutions from a third party vendor such as AJE also provide additional products to bolster
ROI of your recruitment media and advertising program for diversity and inclusion.
Additional Benefits
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Irrelevant ProductsDon’t get sidetracked by products that are not related to
compliance requirements.
EndorsementsRemember that endorsements are nothing but PAID sales
pitches!
Marketing GimmicksBeware of aggressive sales/marketing talk. Stay focused on
what you need.
Exaggerated PromisesDon’t fall for over-promises by vendors exaggerating the
effectiveness of the solution.
Irrelevant ProductsDon’t get sidetracked by products that are not related to
compliance requirements.
EndorsementsRemember that endorsements are nothing but PAID sales
pitches!
Marketing GimmicksBeware of aggressive sales/marketing talk. Stay focused on
what you need.
Exaggerated PromisesDon’t fall for over-promises by vendors exaggerating the
effectiveness of the solution.
What’s Not Important
Completeness/CustomizabilityDoes the solution address the regulation fully and is it
customizable for your business?
Breadth of DistributionDoes the provider maintain a large network of partners for
job distribution?
Reporting and SupportDoes the solution provide easy access to reports and
expert support if your company is audited?
Reputation and Track RecordHow long has the vendor been providing these services and
how satisfied are their customers?
Completeness/CustomizabilityDoes the solution address the regulation fully and is it
customizable for your business?
Breadth of DistributionDoes the provider maintain a large network of partners for
job distribution?
Reporting and SupportDoes the solution provide easy access to reports and
expert support if your company is audited?
Reputation and Track RecordHow long has the vendor been providing these services and
how satisfied are their customers?
What’s Important
Contractors should consider the following criteria when selecting a third party vendor.
Third Party Vendor Selection Criteria
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Legacy of America’s Job BankAJE launched on the same technology platform with the same people
who developed and operated the DOL program.
Backed by a Fortune 500 CompanyAJE is a wholly owned subsidiary of Time Warner Cable with the
financial and technology resources to drive product innovation.
Fast GrowingAJE is one of the fastest growing job boards with an expanding
product line, customer base and partnerships.
Customer CentricAJE products are packaged and optimized to meet the needs of small,
medium and large businesses across industry verticals.
America’s Job Exchange is one of the fastest growing companies in the industry and a
leading provider of recruitment media, advertising and compliance solutions provider.
America’s Job Exchange – A Brief Overview
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America’s Job Exchange - Solution Summary
Several AJE products and servicesare bundled to form the industry’s
most complete Job Listing andDistribution Solution
Industry leading tools, technologiesand live assistance are combined to
offer an unparalleled customerexperience
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CLIENTELE
TRACK RECORD
REPUTATION
Completeness of SolutionBundles several distinct products and services to satisfy the broad
range of tasks required by the regulators.
Customizability of SolutionThe AJE solution is customizable and priced based on your business
needs with variables such as size, hiring forecast and budget.
Breadth of Distribution NetworkBroad network of partners and affiliates including recruitment media
agencies, technology provider, associations and states.
Subsidiary of Publicly Traded CompanyAJE is not a membership-based non-profit association but part of a
customer centric, publicly traded organization you can trust.
The solution from America’s Job Exchange is well differentiated from others.
The AJE Difference
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ComprehensiveUtilize a turnkey set of products and services to fulfill current requirements
and stay abreast of changing regulations with updates and new products.
Cost EffectiveThe cost of services is significantly lower than companies doing the same
work internally or using an agency to do in pieces.
ExpertiseCompliance services being the core offering, third party vendors provide deep
expertise and domain experience to help contractors navigate the regulations.
Third parties such as America’s Job Exchange are a significant resource available to
Federal contractors who must meet the OFCCP compliance regulations in recruitment.
Conclusion
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Thank You
For more information, please contact:
Rathin Sinharsinha@americasjobexchange.com
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