HR Analytical Services

ABOUT HR ANALYTICAL SERVICES

HR Analytical Services provides affirmative action consulting services to companies throughout the United States. Since its founding in 1993, HR Analytical Services has produced thousands of affirmative action plans for small employers, Fortune 500 companies, and every other size of company. We have routinely guided companies through successful affirmative action reviews by the U.S. Department of Labor's Office of Federal Contract Compliance Programs. We partner with our clients to provide them with what they want and what they need. We provide a range of affirmative action consulting services that are meant to meet every client's specific interests.

The types of affirmative action services we provide include the following:

Affirmative Action Plan Development
Assistance With Affirmative Action Compliance Reviews by the OFCCP
Strategic Consulting on Affirmative Action Issues
Management Training on EEO and Affirmative Action
Compensation Analyses
Adverse Impact Analyses

We want to help you make your company's affirmative action efforts a success. We invite you to contact us if you'd like to learn more about our services, the federal government's affirmative action regulations, and how we can make your job simpler by providing the right kind of affirmative action consulting services to your company.

NEWS

OFCCP Releases Corporate Scheduling Announcement Letters

For a number of years, OFCCP has issued letters to certain multi-facility employers advising them that one or more facilities would be underoing an affirmative action compliance review. These letters, called Corporate Scheduling Announcement Letters (CSALs), have generally been sent twice a year. While their use has been somewhat unpredictable, CSALs have been very helpful to large organizations that can use the CSAL list to plan for reviews.

It appears that OFCCP is currently in the process of sending out CSALs for the coming year.

OFCCP Releases Proposed Revisions to Regulations Regarding Persons with Disabilities

On Friday, December 9, the Office of Federal Contract Compliance Programs released proposed revisions to the affirmative action regulations regarding individuals with disabilities. These proposed revisions represent a foundational change in OFCCP's formal expectations regarding the efforts federal contractors and subcontractors must make on behalf of individuals with disabilities. OFCCP has shown a significantly increased focus on disability issues in affirmative action compliance reviews conducted during 2011. The proposed revisions signal a further intensification in the agency's focus.

Reporting Period for 2011 VETS-100/100A Ends January 15, 2012

While the period for federal contractors to file the annual VETS-100/VETS-100A reports would typically close on September 30, the Department of Labor's Veterans Employment and Training Service (VETS) had announced several months ago that companies would not be able to begin filing their VETS-100/VETS-100A reports until November 1. The filing period for the 2011 VETS-100/VETS-100A report was scheduled to close on December 30, 2011, but will now close on January 15, 2012. Federal contractors and subcontractors will NOT be allowed to file a 2011 report after that date. Please note that the data for the VETS-100/VETS-100A will be based on a payroll run during the period from August 1 through September 30. Thus, the filing period and the data period are not the same for this year's report.

Almost all companies should be filing the VETS-100A report rather than the VETS-100 report. The VETS-100 report is required ONLY for companies that have unmodified contracts dating before December 1, 2003. With the many modifications that are routinely made to federal contracts, it would be extremely rare for a federal contractor or subcontractor to have an unmodified contract dating before December 1, 2003.

OFCCP Produces Final Version of Revised Scheduling Letter and Itemized Listing

On May 12, 2011, the Office of Federal Contract Compliance Programs (OFCCP) published proposed major changes to the Scheduling Letter and Itemized Listing that are sent to companies at the start of an affirmative action compliance review. After receiving comments from various members of the public, OFCCP produced what it anticipates will be the final version of the Scheduling Letter and Itemized Listing on September 28, 2011. The final versions of the revised Scheduling Letter and Itemized Listing are basically the same as the proposed versions. If approved, the changes to the Itemized Listing are dramatic and wide-ranging and will have a major impact on the information that companies will need to submit during an affirmative action compliance review.

OFCCP Issues Advanced Notice of Proposed Rulemaking on Compensation

The Office of Federal Contract Compliance Programs has released an Advanced Notice of Proposed Rulemaking (ANPRM) relating to compensation. OFCCP expects to develop a tool that it will use to collect compensation data from federal contractors and subcontractors. The ANPRM can be found at regulations.gov. You can also find the ANPRM on the documents page of our website.

The ANPRM does not replace the compensation guidance issued by OFCCP in 2006. Instead, it seeks to determine how OFCCP should request compensation data. Once OFCCP gathers information, we expect the agency will issue a formal proposal of some kind on compensation later this year or (more likely) in 2012.

For more information on OFCCP's current process for reviewing compensation information, see our news item in this regard.

Read other news including information on OFCCP's recent scheduling letter and veterans proposals.