Although it has been nearly seven years since the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) overhauled its regulations under Section 503 of the Rehabilitation Act (Section 503) and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (Section 4212), it is only more recently that agency compliance officers have now been asking federal contractors for more detailed information on how they evaluate their outreach efforts designed to recruit individuals with disabilities and veterans, respectively.
Among other things, OFCCP’s regulations mandate that contractors: (a) conduct an assessment of outreach annually; (b) document each evaluation; (c) provide the criteria used to evaluate outreach efforts; (d) use eight different “data points” over the last three years as part of the criteria; and (e) provide alternatives for those efforts deemed to be ineffective. Until recently, however, to meet this requirement contractors have been able to provide a brief summary of their outreach efforts by listing the outreach event, the date it occurred, the targeted group, and the outcome (whether it was successful).The following is a useful template for assessing and structuring outreach efforts.
Members of the Center for Workplace Compliance (CWC) can read more here.