Regularly supervises in hand-on manner preparation of clients' affirmative action plans (AAPs) and works with clients' consultants. This includes all details associated with plan creation, such as:
Structure of clients' plans when clients have multiple corporate entities, including some joint ventures
Structure of plans within each site
Composition of job groups
Internal and external feeder jobs and their impact on availability and goals
Impact ratio analyses
Good faith outreach efforts with current emphasis on veterans and disabled persons
Discussion of personnel activity and problem areas
Accessibility of applicant process to disabled persons
4212 report (formerly Vets-100A report)
Advises clients on objections to OFCCP's assertion of jurisdiction and best approaches to achieve administrative closure of audits, such as:
Achieved administrative closure of OFCCP compliance evaluation without conciliation agreement when contractor did not comply with OFCCP’s affirmative action obligations during federal contract or during audit.
Achieved administrative closure of financial technology company’s OFCCP compliance evaluation by demonstrating location under audit was separate from federal contract held by subsidiary.
Achieved administrative closure of financial institution’s OFCCP compliance evaluation by demonstrating contract with an independent federal agency was not a covered federal contract.
Achieved administrative closure of OFCCP compliance evaluation of a company by demonstrating company’s relationship with federal agency was not a covered federal contract.
Achieved administrative closure without violation of OFCCP compliance evaluation of a construction contractor that had not complied with OFCCP obligations before audit.
Counsels construction contractors on practical compliance with federal and state affirmative action programs and projects' numerical goals/benchmarks.
Contributes in the following areas:
Advises on useful metrics and analyses of AAP for communication to senior leadership in easily understandable terms regarding effectiveness of efforts and demonstrable results within bounds of non-discrimination laws.
Creation and implementation of and compliance with vendor diversity programs within the bounds of non-discrimination laws.
Advises local and national clients on OFCCP issues, including creation and structure of AAPs, OFCCP audits, recordkeeping, HRIS issues, and applicant tracking issues.
Advises clients on affirmative action obligations as part of due diligence in acquisitions and analyzes prior efforts and incorporation of new entity’s plans and actions into acquirer’s affirmative action program.