THA Logo_revisedVisit our blog  Follow us on Twitter  View our profile on LinkedIn
HResource

News


October 2014

NATIONAL DISABILITY EMPLOYMENT AWARENESS MONTH
  

Affirmative Action Services

Plan Preparation (OFCCP/FTA)

Compliance Evaluations

Audit Representation

Compensation Evaluation

Interim Reporting

Consulting Services Highlight

 

Compensation Services

 

THOMAS HOUSTON offers clients and non-clients alike a host of compensation consulting services by EEO-1 category, wage/salary grade, Affirmative Action Plan job groups, and/or cohorts (title-by-title). From analyses of base pay, annual bonuses, merit increases, merit increases tied to ratings and relationship to the midpoint, to toal cash compensation -- if it's in a database we can analyze it for you.

 

Mock Audit Services

 

THOMAS HOUSTON can emulate any type of OFCCP or FTA compliance evaluation. A "mock" compliance evaluation is an ideal way to comprehensively assess your company's current compliance status and provide direction for improvement. The different types of "mock" evaluations that can be performed include:

 

  • Desk Audit - A review of the written Affirmative Action Plan and supporting documentation to determine whether all elements required under the regulations are included.
  • On-Site Evaluation - A review that is conducted on-site to further investigate problem areas identified in the desk audit. This will normally involve an examination of your company's Human Resources and employment policies and processes, including selection criteria, as well as an inspection of supporting documentation
  • Off-Site Review of Records/Summary of Findings - An analysis of information gathered during the on-site evaluation followed by a letter outlining areas of non-compliance and corrective action to be taken.

 

If you are interested, please contact us at info@thomashouston.com. A consulting agreement will be sent to you for review and approval.

 

Increased Reporting in OFCCP Revised Scheduling Letter/Itemized Listing

The Federal government fiscal year began October 1st and there have already been big changes in reporting and oversight at the Office of Federal Contract Compliance Programs (OFCCP).

The long-awaited revised Scheduling Letter and Itemized Listing was approved by the Office of Management and Budget (OMB) and published in the Federal Register on September 30th. The Itemized Listing, used in conjunction with the Scheduling Letter, identifies the documents and information that contractors must provide for the desk audit phase of an OFCCP compliance evaluation.

While the Scheduling Letter itself brought non-controversial changes for conformity with recent regulatory changes, the Itemized Listing is an enormous departure from the current desk audit data submission requirements. Of note are the following:

  1. Compensation data will now be required on an individual employee basis with each AAP submission. Previously, only average compensation by male/female, minority/non-minority groupings was required.
  2. Compensation data for contract employees has been added to that of full-time, part-time, per diem, temporary and day laborers.
  3. In addition submitting base wages for each employee, bonuses, incentives, commissions, merit increases, locality pay, overtime and number of hours worked in a typical workweek will be required in separate columns/fields.
  4. Compensation manuals, policies and practices are now required to explain each of the compensation programs listed above.
The revised Itemized Listing continues to permit contractors to submit employment activity data by either job group or job title, but race and ethnicity using specific racial/ethnic sub-categories rather than minority and non-minority will now be required. Among the other additional items required are: an evaluation of the effectiveness of outreach and recruitment of qualified individuals with disabilities and protected veterans; accommodations requested, resolved, and documentation; assessment of personnel practices; and the most recent assessment of physical and mental qualifications, including the date of assessment and next scheduled assessment.

The OFCCP also published that it would not schedule any Supply and Service compliance reviews until after October 15, 2014 to permit contractors a period in which to become familiar with these requirements.

In the OMB approved renewal, the agency is requiring contractors to provide the data electronically but only if they maintain it in an electronic format that is useable and readable.

Click here to link to the OMB site to view the new scheduling letter, compliance check letter and new Itemized Listing.

Source: Office of Management and Budget's Office of Information and Regulatory Affairs (OIRA)
NATIONAL DISABILITY EMPLOYMENT AWARENESS MONTH

Expect. Employ. Empower.

Held each October, National Disability Employment Awareness Month (NDEAM) is a national campaign that raises awareness about disability employment issues and celebrates the many and varied contributions of America's workers with disabilities. The theme for 2014 is "Expect. Employ. Empower." NDEAM's roots go back to 1945, when Congress enacted a law declaring the first week in October each year "National Employ the Physically Handicapped Week." In 1962, the word "physically" was removed to acknowledge the employment needs and contributions of individuals with all types of disabilities. In 1988, Congress expanded the week to a month and changed the name to "National Disability Employment Awareness Month." Upon its establishment in 2001, ODEP assumed responsibility for NDEAM and has worked to expand its reach and scope ever since.

Source: Office of Disability Employment Policy (ODEP)
HAVE YOU BEEN USING E-VERIFY
MORE THAN 10 YEARS?


Effective January 1, 2015, E-Verify transaction records more than 10 years old will be deleted from the system. You will no longer have access in E-Verify to cases you created prior to December 31, 2004. E-Verify is taking this action to comply with the National Archives and Records Administration's retention and disposal schedule.

E-Verify has created a new Historic Records Report. If you want a record of your cases that are more than 10 years old, you must download the new Historic Records Report before December 31, 2014. The report will include all transaction records for cases more than 10 years old. The report is only available until December 31, 2014.

It is a best practice to record the E-Verify case verification number on the related Form I-9. Employers are encouraged to retain the Historic Records Report with the Forms I-9.

If you were not using E-Verify on or before December 31, 2004, you need not download the report. There will be no records to report.

Will E-Verify delete records annually? Yes, E-Verify will delete transaction records more than ten years old annually.

Employers will be advised each year when the Historic Records Report is available for downloading.

For more information and guidance on downloading see the Fact Sheet and Instructions.

Source: U.S. Citizenshp ad Imigration Services (USCIS)
This information is intended to be informative
and should not be considered legal advice on any specific matter
To schedule an appointment to discuss our services click here
COMPLIANCE UPDATES

EAF_new 
Members Are Eligible
for a Discount

TRAINING

Click here to view our eLearning Library and HRCI accredited courses

Metropolitan Washington, DC
703.481.9839

www.thomashouston.com

Ft. Lauderdale, FL
954.916.9290