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Additional training for Compliance Officers is planned for 2005. Training will focus on statistics in compensation and adverse impact analysis. New investigative and interview techniques will be emphasized.
OFCCP plans to revamp their internal computer systems. More information on companies will be available to the OFCCP: (e.g. previous compliance review results, current federal government contracts
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so District Offices do not have to ask companies scheduled for audits if they have federal contracts).
Expect to see some new management teams at the OFCCP. The entire NE Region (NY) management has already been replaced.
More statisticians will be hired to review cases for litigation worthiness. Dr. Richard Fisher has already been hired to review test validity
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studies.
More emphasis will be placed on identifying systemic discrimination. See the related article on the new FCSS selection system.
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New Compliance Manual should be available during 2005.
Compliance Officers appear to be using the following applicant definition:
1. Is the person "minimally qualified" for the job at issue,
2. "Applied" for the openings in question (or wanted to apply, but did not because he or she was deterred by the known prospect of discriminatory rejection), and
3. "Considered" (or should have reasonably considered) for the opening in question.
If an issue related to an AAP audit is decided by an Administrative Law Judge, it is now reviewed by an Administra
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tive Review Board (ARB). The Secretary of Labor previously made the final determination. The ARB has 1 year to make a decision. The Secretary of Labor previously had no time limit.
If past experience is any indication, future AAP reviews will last longer and require tremendous HR resources. OFCCP has been spending an average of 140 hours on each review before initiating this new selection method. Cases will be allowed to stay open much longer now.
EO Survey will probably be issued again in 2005.
The OFCCP is not consistent on whether part-timers should be included in an affirmative action plan. By "podium pol
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icy" the OFCCP has stated part timers should be included , but many AAP's that excluded them have been approved.
For those who used the 1990 Census data broken down by income level, this break down is not available for 2000 census.
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