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Let me preface this blog post with a disclaimer. I am not a lawyer and do not work for the US Department of Labor or any other government agency. I performed some research on behalf of one of my clients who is currently implementing SF Recruiting Management and wanted to know how they would be able to become compliant. Be sure to consult with your own legal department before implementing any of the changes below. Each organization can have a slightly different interpretation of the regulations.

Background

What is the background behind these new amendments? One rule updates requirements under the Vietnam Era Veterans’ Readjustment Assistance Act of 1974; the other updates those under Section 503 of the Rehabilitation Act of 1973. Both of them have the goal of improving the hiring and employment of veterans and for people with disabilities. Who is subject to these laws? Any organization that does business with the US federal government, either as a contractor or subcontractor.

The VEVRAA rule provides contractors with a quantifiable metric to measure their success in recruiting and employing veterans by requiring contractors to annually adopt a benchmark either based on the national percentage of veterans in the workforce (currently 8 percent), or their own benchmark based on the best available data.

The Section 503 rule introduces a hiring goal for federal contractors and subcontractors that 7 percent of each job group in their workforce be qualified individuals with disabilities. The rule also details specific actions contractors must take in the areas of recruitment, training, record keeping and policy dissemination.

Both regulations have requirements that impact recruiting implementations, namely data collection, invitation to self-identify and record access (i.e. reporting). Again, this blog post is not meant to be a comprehensive explanation of all of the regulations, and only highlights some key points.

DOL VEVRAA Ruling

The Final Rule was published in the Federal Register on September 24, 2013, and becomes effective on March 24, 2014. However, current contractors with a written affirmative action program (AAP) already in place on the effective date have additional time to come into compliance with the AAP requirements. The compliance structure seeks to provide contractors the opportunity to maintain their current AAP cycle.

Data Collection

The Final Rule requires contractors to invite applicants to self-identify as a protected veteran prior to making a job offer, in addition to the post-offer self-identification that is already required.

Invitation to Self-Identify

The pre-offer invitation to self-identify may be included in the contractors’ application materials. After making a job offer to an applicant, the Final Rule retains the existing obligation that the contractor invite the applicant to voluntarily self-identify as belonging to any of the specific categories of protected veteran (e.g., recently separated veteran; disabled veteran) on which the contractor is required to report by the Veterans Employment and Training Service (VETS).

Appendix B of the Final Rule includes a sample invitation to self-identify that contractors may choose to use. You can find the sample invitations on the OFCCP Web site.

Record Access

Federal contractors and subcontractors need to be able to provide OFCCP officials access to AAP records, hiring reports, etc. To do so, clients need to ensure their reports are configured with the required OFCCP data.

What it Means to SAP and SuccessFactors Recruiting Clients

SuccessFactors customers can include invitation to self-identify questions as part of the application process. Veteran Status is defined as a standard field (veteranStatus) for the application form and can therefore be included on the application form, as well as in reports using the Ad Hoc Reporting tool. 

SAP customers can create questions to collect this data and include them as part of application process. For reporting, custom development will need to be done to read the questionnaire data and make it accessible to Business Warehouse via custom extractors or as Infoset enhancements to SAP Query. Custom queries will also need to be defined in SAP BW, SAP Query, or as an ABAP report.

DOL 503 Disability Ruling

Data Collection

The Final Rule requires contractors to invite applicants to self-identify as a protected veteran prior to making a job offer, in addition to the post-offer self-identification that is already required.

Invitation to Self-Identify

The Final Rule requires that contractors invite applicants to self-identify as individuals with disabilities (IWD) at both the pre-offer and post-offer phases of the application process, using language prescribed by OFCCP.

The pre-offer invitation to self-identify may be included in the contractors´ application materials for a position, but must be separate from the application. OFCCP is developing a form for contractors to use to invite applicants to self-identify and will post it on the OFCCP Web site when it becomes available. Clients may create an electronically fillable version of the form used to invite self-identification provided that form meets certain requirements set forth by the OFCCP.

Record Access

Federal contractors and subcontractors need to be able to provide OFCCP officials access to AAP records, hiring reports, etc. To do so, clients need to ensure their reports are configured with the required OFCCP data.

What it Means to SAP and SuccessFactors Recruiting Clients

SuccessFactors customers will most likely need to implement multi-stage applications to cover this requirement since this information must be collected separate from the application. Disability Status is defined as a standard field (disabilityStatus) for the application form and can therefore be included in reports in Ad Hoc Reporting.

SAP customers can configure a questionnaire to collect this data and send it to candidates via email separate from the application. For reporting the same effort would need to be undertaken as for the VEVRAA ruling requirements.

Where Can I Learn More?

DOL announcement: 
 http://www.dol.gov/opa/media/press/ofccp/OFCCP20131578.htm

DOL VEVRAA ruling:

http://www.dol.gov/ofccp/regs/compliance/vevraa.htm

DOL 503 disability ruling:

http://www.dol.gov/ofccp/regs/compliance/section503.htm

Note: if you are a SuccessFactors partner, you can also download their customer-facing solution brief.

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