Direct Compliance FAQs
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Q: Distribution of federal contractor’s jobs to the State and local employment delivery systems is a big job. Who else does Direct Employers Association work with to administer the program and deliver jobs as required by the Jobs for Veterans Act?
A: When we talk about the VetCentral staff, we are not only talking about our internal staff but also our partners who have worked with us in the design, development, and management of this important project:
2) XPAND Corporation, a pioneer in advanced technologies with many years of experience working with the U.S. Department of Labor, Veterans’ Employment & Training Service (VETS) and OFCCP.
3) Two former U.S. Department of Labor Employment and Training Administration executives, Dave Morman and Jim Vollman. Both have extensive experience in the design, development, and management of America’s Job Bank (AJB). Dave Morman has previously served as the Executive Director of the Veterans Employment and Training Service (VETS). Jim Vollman is an attorney and former Associate Assistant Secretary for the Employment and Training Administration (ETA) at the U.S Department of Labor
Q: Our company lawyers are interpreting the OFCCP compliance as our company has to have the job listed on that state site to be compliant. Is this correct?
A: The appropriate employment service delivery system can be either the State job bank or the local office nearest where the job is to be filled. The addition of the State job bank as a compliance option was a major change from the OFCCP preliminary and final rules. It was added as a convenience and not to replace the option of delivery to local offices.
The key to compliance for the employer/contractor is not what action the State or local office takes on the job but rather the act of “submitting” or “transmission” of the job to the appropriate place. OFCCP in preamble to its final rule stated: “A contractor may satisfy the mandatory job listing requirement by submitting job listings to the appropriate employment delivery system in a variety of ways, including via mail, facsimile (FAX), electronic mail, or other electronic postings. Contractors may use third parties to assist them with the transmission of job postings to the appropriate employment delivery system.”
Q: How is Direct Employers confirming, in its VetCentral system and the related OFCCP job report, that the jobs are being delivered?
A: The VetCentral system follows the guidance that OFCCP has given on what contractors must do to handle problems with delivery. The VetCentral system will first attempt an e-mail delivery of the job to the appropriate local office (or through a download to the State job bank). Each delivery attempt is recorded (addressee, e-mail address, time, and result). If the attempt is successful, that information is then made part of the reports’ audit trail. If it is not successful (no delivery receipt is returned by the addressee’s e-mail server), additional e-mail attempts will be made over the next few hours. If successful, the entire record will be made part of the audit trail. If not, fax delivery will be attempted and the information (addressee, fax number, time, and result) will be recorded. If successful, that information will be added to the report and the audit trail. If not, the job will be added to the queue for U.S. Priority Mail fulfillment with that information also recorded and added to the audit trail. Where delivery problems are occurring, VetCentral staff will reach out to the local office to determine if there is a problem with the e-mail address or fax number.
Q: How long will our reports be available on Member Desktop?
A: Five years.
Q: JobCentral is claiming they are delivering my jobs to the state and local Employment offices, but when my boss/compliance officer called the local employment office closest to our headquarters, he was told by the manager that my jobs are not being delivered. What should I do?
A: Call your Member Services Specialist to troubleshoot the situation and find resolution.
Possible causes:
- Addressee out of office
- Misdirected email
- Undeliverable, still in process
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