By: Connie Maniscalco on April 2nd, 2014

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Best Ways to Demonstrate "Good Faith" Recruiting Efforts

Risk Management

Just this past week the new rules by the Office of Federal Contracting Compliance Programs (OFCCP) went into effect in an effort to strengthen the recruitment efforts by government contractors to hire more veterans and persons with a disability.  As a government contractor compliance SME, we hear a great deal about “good faith efforts” when it comes to recruiting but as a government contractor how do you exhibit the “good faith efforts” to the OFCCP if your company has been selected for an Affirmative Action Plan (AAP) audit?

By including the following activities as a part of your recruitment process your company will be positioned to demonstrate your good faith efforts:

  • Establish a standard operating procedure to post all open positions (with the exception of those jobs lasting 3 days or less) with the local employment offices in the states where the company operates and allow veterans to view the job postings first, prior to opening them up to the general public.
  • Establish partnerships with one of the many veteran outreach organizations and post all open positions with those organizations.
  • Attend job fairs hosted by veteran outreach organizations and consider hosting a job fair if the opportunity arises.
  • Research organizations designed to promote individuals with disabilities such as The National Organization on Disability ( and the Job Accommodation Network ( to learn about the recruiting resources in place for employers.
  • Contact your local Easter Seals organization and create a partnership to post all open positions with the local chapter.

So what if after all of these efforts your organization still does not meet the new aspirational 7% employment goal of hiring individuals with a disability as well as an 8% hiring benchmark for protected veterans under VEVRAA (Vietnam Era Veterans’ Readjustment Assistance Act)?  As long as your organization is targeting these populations and considering them for employment in your recruiting standard operating procedure then your organization is exhibiting your good faith recruiting efforts.

To view the press release by the National Organization on Disability and the new OFCCP rules click on the following link: