In a typical compliance evaluation, the Office of Federal Contract Compliance Programs (OFCCP) will often demand documented evidence of the company’s “good faith efforts” to meet its compliance obligations. Indeed, complete and accurate documentation can be key to verifying that the company is engaging in affirmative action as required, as well as demonstrating that the company’s efforts are compliant. Further, federal contractors are also required to annually assess their good faith efforts for individuals with disabilities and protected veterans.

Many employers have found that securing “buy-in” from the Talent Acquisition professionals — who do not typically report to the Compliance team, but nonetheless are typically tasked with executing and documenting the company’s good faith efforts — can be a challenge. Success or failure can often depend on how much extra effort is involved, creating a tension between the desire for complete documentation and the challenge of getting any documentation at all.

To that end, we have prepared this guide to tracking good faith efforts, including a sample spreadsheet with a “best practices” set of data fields for tracking and assessing good faith efforts.

Members of the Center for Workplace Compliance (CWC) can read more here.   URL for “here”: