Compliance with Good-Faith Outreach and Recruiting Efforts as a Federal Contractor

Introduction

For federal contractors, demonstrating Good-Faith Efforts in recruitment is essential to meeting affirmative action obligations and complying with federal labor standards. Good-Faith Outreach and Recruiting Efforts go beyond standard hiring practices; they require a proactive and intentional approach to recruiting, with a focus on engaging diverse communities and expanding access to job opportunities for underrepresented groups.

This blog provides an overview of Good-Faith compliance requirements for federal contractors and offers practical guidance on developing outreach and recruiting strategies that support compliance and promote a more inclusive workplace.

What Are Good-Faith Outreach and Recruiting Efforts?

Good-Faith Efforts refer to proactive steps taken by federal contractors to recruit, hire, and promote individuals from diverse backgrounds, including minorities, women, veterans, and individuals with disabilities. For federal contractors, compliance with Good-Faith Efforts is more than a requirement—it reflects a commitment to equal opportunity and inclusive hiring practices.

The Office of Federal Contract Compliance Programs (OFCCP) oversees compliance for federal contractors, ensuring they meet standards set by laws such as Executive Order 11246, Section 503 of the Rehabilitation Act, and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). Under these regulations, contractors must demonstrate that they are actively working to attract and consider qualified candidates from all backgrounds.

Key Good-Faith Compliance Requirements for Federal Contractors

To meet Good-Faith compliance standards, federal contractors must implement targeted recruitment and outreach practices, track their efforts, and document their results. Here are some of the primary requirements for Good-Faith Outreach and Recruiting Efforts:

1. Targeted Recruitment for Diverse Talent Pools. Federal contractors are required to actively reach out to job seekers from underrepresented groups, including women, minorities, veterans, and individuals with disabilities. This targeted outreach ensures that contractors are not only open to diverse candidates but are taking deliberate steps to invite and encourage their participation in the hiring process.
   • Executive Order 11246: Requires affirmative action to ensure equal employment opportunities for women and minorities.
   • Section 503 of the Rehabilitation Act: Mandates affirmative action for individuals with disabilities.
   • VEVRAA: Requires proactive recruitment and outreach for protected veterans.
2. Developing an Affirmative Action Plan (AAP). Service and Supply Contractors with 50 or more employees and federal contracts valued at $50,000 or more are required to create and maintain an written Affirmative Action Plan (AAP). An AAP outlines the contractor’s commitment to Good-Faith Efforts, setting specific goals for diversity and inclusion in the workforce.
   • Diversity Goals: AAPs include specific numerical goals or benchmarks for hiring individuals from underrepresented groups, based on workforce availability and local labor demographics.
   • Measurable Objectives: Contractors must document recruitment and outreach strategies, including targeted efforts to reach diverse job seekers.
3. Building Partnerships with Community Organizations. To support Good-Faith recruiting efforts, federal contractors are encouraged to develop partnerships with local organizations that work with minority groups, veterans, and individuals with disabilities. These partnerships help expand the contractor’s reach and support compliance by actively engaging with the communities they aim to hire from.
   • Community and Non-Profit Organizations: Partner with organizations that serve underrepresented communities, such as workforce development centers, disability advocacy groups, and veteran service organizations.
   • Educational Institutions: Collaborate with vocational schools, community colleges, and universities to connect with recent graduates and those in training programs that align with your industry.
4. Job Posting and Outreach Requirements. Under VEVRAA, federal contractors must post job openings with state workforce agencies or appropriate local job banks to ensure veterans have access to these opportunities. Similarly, contractors are encouraged to post jobs with organizations and job boards that serve other underrepresented groups, ensuring equal access to employment opportunities.
   • State Employment Services: By posting jobs with state and local employment agencies, contractors improve access to job opportunities for veterans and other targeted groups.
   • Outreach Channels: Use specialized job boards, diversity-focused career fairs, and targeted advertising to reach a broad and diverse applicant pool.
5. Documenting and Reporting Outreach Efforts. For Good-Faith Efforts to be recognized, federal contractors must keep thorough records of their recruiting activities and the outcomes of their outreach. Documentation is critical, especially during audits or compliance reviews conducted by the OFCCP.
   • Tracking Outreach Activities: Record each community partnership, job fair, job posting, and targeted recruitment effort, including details on the demographics reached and the results of each activity.
   • Compliance Reporting: Contractors must file reports such as the EEO-1, VETS-4212, and other documentation required to demonstrate compliance with affirmative action goals and Good-Faith Efforts.

Best Practices for Achieving Good-Faith Compliance

To ensure compliance with Good-Faith recruiting standards, federal contractors can implement the following best practices:

1. Develop Targeted Recruitment Campaigns. Tailor recruitment campaigns to reach specific communities, including veterans, individuals with disabilities, and minority groups. This may include attending diversity-focused job fairs, advertising in publications targeted to underrepresented groups, and working with local workforce development agencies.
2. Provide Training for Hiring Teams. Educate hiring managers and HR staff on Good-Faith Efforts, emphasizing the importance of diversity and inclusion in recruitment. Training programs should cover topics such as inclusive interviewing techniques, understanding bias, and interpreting affirmative action goals.
3. Implement Effective Tracking and Reporting Systems. Use applicant tracking systems (ATS) and other technology to monitor the success of outreach activities, from applicant demographics to hiring outcomes. Detailed tracking supports both internal assessments and external compliance reviews, ensuring that contractors meet their Good-Faith obligations.
4. Evaluate and Adjust Outreach Efforts Regularly. Regularly review the effectiveness of your outreach and recruitment strategies. This may include assessing the diversity of your applicant pool, tracking how many hires come from targeted outreach activities, and making adjustments as necessary to improve results and support compliance.
5. Engage with Compliance Consultants or Specialists. Navigating Good-Faith compliance requirements can be complex. Working with compliance consultants or HR specialists experienced in federal contractor obligations can help ensure your organization meets regulatory standards and optimizes its Good-Faith recruiting efforts.

Benefits of Good-Faith Recruitment Compliance

Maintaining compliance with Good-Faith Efforts offers several advantages for federal contractors:

• Enhanced Workforce Diversity: A focus on Good-Faith Efforts ensures a diverse candidate pool, which can lead to a more dynamic, innovative workforce.
• Reduced Risk of Penalties: Compliance reduces the risk of penalties, contract loss, or reputational damage that may result from OFCCP audits or investigations.
• Positive Employer Brand: Demonstrating a commitment to Good-Faith recruiting enhances your reputation as an inclusive employer, making it easier to attract top talent.

Conclusion

Good-Faith Outreach and Recruiting Efforts are essential for federal contractors striving to maintain compliance and build a fair, inclusive workplace. By implementing proactive recruitment strategies, building community partnerships, and carefully tracking recruitment activities, contractors can meet federal requirements while supporting a diverse workforce. For companies committed to compliance and long-term success, Good-Faith Efforts are a valuable investment in both talent and reputation.

At Jobs4More, we understand the importance of compliance with Good-Faith recruiting standards. If your organization needs assistance developing a compliant recruitment strategy or implementing effective outreach practices, we’re here to help. Contact Jobs4More today for expert guidance on building community partnerships and ensuring your company’s Good-Faith Efforts are impactful and compliant.