December 23, 2020
Merry Christmas from Kairos!

Merry Christmas from all of us at Kairos Services! Thank you for being our valued client. We pledge to work with you to achieve 100% compliance and we promise not to take your business for granted.

We know you have options and we are honored you have chosen us. We look forward to serving you in 2021 and, as always, our phone lines and doors are open if any need or questions should arise.

Here is a short message from the children of Kairos to you and your family.

November 11, 2020
In Honor of Veterans Day

Veterans Day is largely an occasion when we take the time to recognize and honor living veterans for their sacrifices; it is a day that we honor all those who have served our country whether in war or peace time. President Woodrow Wilson proclaimed Armistice Day, as it was originally called, in 1919 on the first anniversary of the end of World War I.

Although every day is a good day to thank a veteran, on this special day we honor and thank every veteran who has left their family to protect our country and our freedoms. Kairos encourages you to honor the service of veterans in your family, workforce, and community.

September 22, 2020
In Honor of National Hispanic Heritage Month

In 1968 President Lyndon Johnson began the observance of Hispanic Heritage Week. Twenty years later, President Ronald Reagan expanded Heritage Week to cover a 30-day period from September 15 to October 15 by signing Public Law 100-402.

How to celebrate? Scholastic Magazine and Good Housekeeping have released suggestions for celebrating. Here are ours:

Happy National Hispanic Heritage Month!!

September 17, 2020
OFCCP CSAL List Update

On September 11, Kairos reported that OFCCP added 2,250 audits to their CSAL list. See the post here. Today, September 17, the CSAL list released was revised. OFCCP kept the total reviews and counts of review by type the same, swapping review types for 80+ audits – about half from promotion reviews to establishment reviews and the other half from establishment to promotion. Visit OFCCP’s website here to view the updated list.

September 11, 2020
OFCCP Adds 2,250 New Audits to Its List

OFCCP just released a new list of companies it will be auditing for both Supply & Service and Construction reviews in the OFCCP Freedom of Information Act (FOIA) Library. OFCCP added two brand-new review types, “Accommodation Focused Review,” “Promotion Focused Review,” and “Construction Compliance Check” – though it has yet to release any information about the format or content of these reviews.

We have reviewed the CSAL list and reached out to you already if we have identified your location on the list, though we recommend you review the list just in case we missed it – searching by both address, company name, and establishment name columns.

These audits may only begin to be scheduled in the next 9-12 months (or longer) – but that is no excuse to wait until it is too late to make sure you are compliant. OFCCP is being extremely meticulous in its latest Section 503 audits, aggressively enforcing compliance with veterans and individuals with disabilities regulations as well as increasing their focus on hiring and compensation disparities.  Ensure proper data collection and recordkeeping systems are in place and all required positions are being listed with the local State Employment Services. Take the time to conduct your annual documented VEVRAA and Section 503 Self-Audit (see our portal for a word-version of the form).

August 16, 2020
Nicolas Paul Presents “AAP Reports: Metrics & Analysis” at National HR Conference

AAP Reports: Metrics & Analysis

Nicolas Paul (Kairos) and Patrick Nooren (Biddle)

Tue, Aug 18, 2020, 2020, 2:00 PM – 3:15 PM EDT

Learn to map job titles to census codes, identify feeder pools, assign weights and determine labor areas. If results don’t look reasonable, what are the options? This workshop covers the impact of job group creation on goals, disparities and compensation. Instructions are provided to help you perform analysis on under-utilization, data collection, outreach, comparing applicant data to external availability and identification of trends. How to use AAP metrics for your Diversity & Inclusion initiatives will also be reviewed.

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View the recorded webinar at https://nilgconference.com/completed-webinars/.

May 07, 2020
COVID-19 Resources

Kairos recently update our Client Portal to include what you should know about COVID-19 and the ADA. On the website you will find technical publications, PowerPoint presentations, videos, and links to EEOC’s Questions & Answers. Visit our Portal at https://kairosservicesinc.com/kairos-client-portal/ and scroll to “COVID-19 Guidance”.July 31, 2020

Self-ID and Vets-4212 Reporting Updates

Voluntary Self-Identification of Disability Form (CC-305)

Kairos would like to remind you that today, August 4, 2020, is the deadline to incorporate the updated Voluntary Self-Identification of Disability Form (CC-305) into your applicant and human resource systems and processes.

The form can be downloaded at the Kairos Client Portal under “Self-Identification Forms”. Use this direct link to form CC-305 to download the form. If you have any questions please reach out to Nick Paul (Nick@KairosServicesInc.com).

VETS-4212 Federal Contractor Reporting

The Vets-4212 reporting system is open and the deadline, September 30, will be here before you know it! In the event of an OFCCP audit you should expect to be asked to provide copies of your reports so be sure you save a copy when you finished submitting. Federal contractors are required to file Vets-4212 reports if they meet the requirements.

Who is required to file?

All nonexempt Federal contractors and subcontractors with a contract or subcontract in the amount of $150,000 or more with any department or agency of the United States for the procurement of personal property or non-personal services.

When do you file?

The online system is open for filing through September 30.

Need some help?

As a courtesy to our clients, we can review your reports and compare them to your AAP for consistency in reporting. If you are interested, we can also prepare your Vets-4212 reports for you. Just email me with questions or for pricing information (Jen@KairosServicesInc.com).

April 17, 2020
OFCCP Scheduling Letters Approved

Compliance Evaluations Continue

We understand that many of our HR contacts are extremely busy and focusing on employee relations and COVID related matters. However, please do not let your guard down on compliance. OFCCP continues to operate and is moving forward on existing audits, while also scheduling new audits. It is ‘business as usual’ for both OFCCP and EEOC. The EEOC just released a bulletin that includes updated guidance about return-to-work situations, making reasonable accommodations, and harassment. The bulletin can be found at the following link.

OMB Approves “New” OFCCP Scheduling Letters – Spoiler Alert – No Major Changes!

The Office of Management and Budget (OMB) reviewed comments and approved OFCCP’s compliance audit scheduling letters that will be sent to Supply & Service Contractors for the next three years, until April 2023. The letters included in OMB’s approval include: Compliance Evaluations, Compliance Checks, Section 503 Focused Reviews and VEVRAA Focused Reviews. The approved letters saw no significant changes from OFCCP’s current letters. Although a few minor changes did occur, they do not constitute significant changes to the compliance audit process. The letters are available on OMB’s website at the following link.

EEO-1 Reporting

The EEO-1 portal continues to remain closed. The public has until April 22 to comment on the EEOC’s request for approval from OMB, for the collection of Component 1 Data. Kairos does not expect to see the EEO-1 portal open until mid-year 2020.

March 23, 2020
UPDATE: 2019 COMPONENT 1 EEO-1 Survey

The EEOC is currently in the process of seeking approval under the Paperwork Reduction Act (PRA) to collect the EEO-1 survey for 2019, 2020, and 2021.  The EEOC is seeking to collect Component 1 of the survey and to discontinue the collection of Component 2 pay data.  See, EEO-1 30-Day PRA Notice. The opening of the collection, as well as the new deadline date, will be announced by posting a notice on the EEOC home page and sending a notification letter to eligible EEO-1 filers. When the survey opens, the EEOC will provide online resources to assist filers with their submissions and the EEOC’s helpdesk will be available to respond to filer inquiries and to provide additional filing assistance (including, for example, guidance on processing mergers and acquisitions and other corporate changes).

March 20, 2020
OFCCP COVID-19 Response

OFCCP COVID-19 Response

In light of the current COVID-19 pandemic, OFCCP is reaching out to ensure you know the agency is continuing to pursue its important mission of ensuring equal employment opportunity while making adjustments to ensure all of its activities are consistent with current public health guidelines. For example, OFCCP will continue to provide resources and assistance to workers and the contractor community through its website, Help Desk, and Contractor Assistance Portal, although local offices will no longer be accepting walk-ins until further notice.

Likewise, OFCCP will continue its compliance reviews, focused reviews, and complaint investigations, but in lieu of physical onsites, OFCCP will maximize use of every alternative resource available, such as WebEx, Skype, and phones to conduct interviews and complete our evaluations.

If contractors are experiencing difficulty in having their employees accessible during a review or experiencing any other challenges related to the health crisis, OFCCP will remain flexible by coordinating with them and providing reasonable extensions where needed.  Contractors and complainants should reach out to their local OFCCP point of contact to check the status of open evaluations and investigations.

OFCCP will make every effort to continue assessing the effects of the health crisis on our activities and will provide updates to our stakeholder community as soon as possible.

If you need assistance with any other OFCCP matters related to the health crisis, please contact our Help Desk at 1-800-397-6251.  The hearing impaired may call the text telephone (TTY) at 1-877-889-5627 or submit an inquiry online.

March 18, 2020
OFCCP Update Regarding COVID-19

Federal contractors impacted by COVID-19 can request extensions of time to respond to Scheduling Letters and requests for information. The OFCCP is also currently considering the use of video conferencing to continue conducting compliance reviews.

Read more at and https://www.dol.gov/sites/dolgov/files/OFCCP/National-Interest-Exemption-Memo-Coronavirus-Relief-Efforts.pdf

March 17, 2020
The Coronavirus, the ADA and the Rehabilitation Act

What You Should Know About the ADA, the Rehabilitation Act, and COVID-19

  • The ADA and Rehabilitation Act rules continue to apply, but they do not interfere with or prevent employers from following the guidelines and suggestions made by the CDC or state/local public health authorities about steps employers should take regarding COVID-19. Employers should remember that guidance from public health authorities is likely to change as the COVID-19 pandemic evolves. Therefore, employers should continue to follow the most current information on maintaining workplace safety.
  • The EEOC has provided guidance (a publication entitled Pandemic Preparedness in the Workplace and the Americans With Disabilities Act), consistent with these workplace protections and rules, that can help employers implement strategies to navigate the impact of COVID-19 in the workplace. This pandemic publication, which was written during the prior H1N1 outbreak, is still relevant today and identifies established ADA and Rehabilitation Act principles to answer questions frequently asked about the workplace during a pandemic.
  • The World Health Organization (WHO) has declared COVID-19 to be an international pandemic. The EEOC pandemic publication includes a separate section that answers common employer questions about what to do after a pandemic has been declared. Applying these principles to the COVID-19 pandemic, the following may be useful:
    • How much information may an employer request from an employee who calls in sick, in order to protect the rest of its workforce during the COVID-19 pandemic?
      • During a pandemic, ADA-covered employers may ask such employees if they are experiencing symptoms of the pandemic virus. For COVID-19, these include symptoms such as fever, chills, cough, shortness of breath, or sore throat. Employers must maintain all information about employee illness as a confidential medical record in compliance with the ADA.
    • When may an ADA-covered employer take the body temperature of employees during the COVID-19 pandemic?
      • Generally, measuring an employee’s body temperature is a medical examination. Because the CDC and state/local health authorities have acknowledged community spread of COVID-19 and issued attendant precautions, employers may measure employees’ body temperature. However, employers should be aware that some people with COVID-19 do not have a fever.
    • Does the ADA allow employers to require employees to stay home if they have symptoms of the COVID-19?
      • Yes. The CDC states that employees who become ill with symptoms of COVID-19 should leave the workplace. The ADA does not interfere with employers following this advice.
    • When employees return to work, does the ADA allow employers to require doctors’ notes certifying their fitness for duty? 
      • Yes. Such inquiries are permitted under the ADA either because they would not be disability-related or, if the pandemic influenza were truly severe, they would be justified under the ADA standards for disability-related inquiries of employees. As a practical matter, however, doctors and other health care professionals may be too busy during and immediately after a pandemic outbreak to provide fitness-for-duty documentation. Therefore, new approaches may be necessary, such as reliance on local clinics to provide a form, a stamp, or an e-mail to certify that an individual does not have the pandemic virus.
    • If an employer is hiring, may it screen applicants for symptoms of COVID-19?
      • Yes. An employer may screen job applicants for symptoms of COVID-19 after making a conditional job offer, as long as it does so for all entering employees in the same type of job.  This ADA rule applies whether or not the applicant has a disability.
    • May an employer take an applicant’s temperature as part of a post-offer, pre-employment medical exam?
      • Yes.  Any medical exams are permitted after an employer has made a conditional offer of employment.  However, employers should be aware that some people with COVID-19 do not have a fever.
    • May an employer delay the start date of an applicant who has COVID-19 or symptoms associated with it? 
      • Yes.  According to current CDC guidance, an individual who has COVID-19 or symptoms associated with it should not be in the workplace.
    • May an employer withdraw a job offer when it needs the applicant to start immediately but the individual has COVID-19 or symptoms of it?
      • Based on current CDC guidance, this individual cannot safely enter the workplace, and therefore the employer may withdraw the job offer.

Feb 17, 2020
National Conference Presentations

Kairos management team members Nick Paul, Jennifer McAlister and Will Waymel were recently accepted as speakers at the 2020 National Industry Liaison Group (NILG) Conference to be held this July in National Harbor, Maryland. Norma Brito was selected to lead the full day Foundations Workshop in the preconference. The NILG Conference is the ‘must attend’ conference for those involved in affirmative action, equal employment opportunity, and diversity & inclusion. Learn more at the Conference Website.

Feb 03, 2020
OFCCP Director Leen Nominated for Inspector General at the Office of Personnel Management

On February 3, 2020, the White House announced President Trump’s intent to nominate Craig Leen for the Inspector General at the Office of Personnel Management. Leen currently serves as the Director of the Office of Federal Contract Compliance Programs (OFCCP) at the Department of Labor. Read more at the Whitehouse.gov.

January 29, 2020
Another Batch of Disability Focused Reviews Scheduled

The OFCCP released a new batch of Disability Focused Review scheduling letters, currently being received by Federal contractors in the Southwest and Rocky Mountain (SWARM) Region. The SWARM region includes Arkansas, Colorado, Louisiana, Montana, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, Utah, and Wyoming. Kairos has contacted clients on the scheduling list. For more information please visit Kairos’ website.

January 28, 2020
Disability Form CC-305 Expiration

While the Voluntary Self-Identification of Disability Form (CC-305) expired January 31, 2020, OFCCP has directed Federal contractors to continue using the current expired form until the Office of Management and Budget (OMB) approves changes to the proposed form, expected to be released this spring. Kairos will alert our clients when the approved form is released. For more information visit OFCCP’s Self-Identification Form website.

January 15, 2020
EEO-1 Survey Portal Remains Closed

The EEOC announced that the EEO-1 Survey Portal will remain closed until last year’s collection of Component 2 Pay Data reaches the threshold required by Federal court order. Until then, the EEOC has suspended filing, notification letters, and assistance related to 2019 submissions.

This is not the first time the EEO-1 Survey Portal has been delayed. Federal contractors can expect an extension beyond the typical March 31 deadline, once the portal opens. For more information visit the EEO-1 Survey website.

January 01, 2020
2010 Census Website Change

Preparations are currently being made for The U.S. Census Bureau’s launch of the 2020 decennial census. The American FactFinder (AFF) census site will be taken offline on March 31, 2020. Most data previously released on AFF will now be released on the U.S. Census Bureau’s new dissemination platform, data.census.gov. Census data collected from the decennial census is usually unavailable for AAP reporting until two to three years after the census begins.

November 28, 2019
Thanksgiving Message to Our Clients

We are thankful to have clients like you – not just on Thanksgiving but every day. Please know that we count you among our blessings.

Norma Brito – Chief Executive Officer
Nicolas Paul – Director of Compliance
Jennifer McAlister – Director of Operations
William Waymel – Director of Audit Services

November 11, 2019
Veteran’s Day 2019

This Veteran’s Day Kairos encourages you to honor the service of veterans in your workforce and community.

For additional outreach and inclusion resources and suggestions please visit our portal.

November 11, 2019
Nicolas Paul Selected as Keynote Speaker for Airbus Veteran’s Day Event

Nicolas Paul was selected as the keynote speaker for Airbus’ Veteran’s Day event this year.  Mr. Paul has recently begun to share his story of trauma, PTSD and healing.  Learn more by reading excepts below from his LinkedIn page.

November 1, 2019

PTSD. This condition impacts 50% of the 3 million soldiers that have deployed to combat in Iraq and Afghanistan over nearly 20 years of sustained military operations. Instead of inundating you with more regs training, I’m going to give you the tools necessary to better understand PTSD, and provide guidance to make REAL change happen. This ‘invisible wound’ of war is far too prevalent to deserve anything less than our greatest attention. Over the next several days we’re going to focus on what PTSD is (definition/identification), how it manifests differently in veterans that experience the same trauma, we’ll cover different treatments, stories and experiences, with my own personal military stories (3rd Ranger Battalion) of loss, guilt, and trauma. Many veterans don’t know what they don’t know. YOU can be the light for them to follow! You’re reading this because you’re a change maker. Let’s get the word out and train more HR Professionals over the next several days!

November 8, 2019

Imagine the deafening roar of engines as you stand second in the door of a C-130 that’s been flying low and fast through hours of darkness, preparing to jump ahead of conventional U.S. forces into the Iraqi desert. Your mission, secure critical assets and eliminate the enemy’s ability to wage war. Standing in the doorway of the aircraft moments before exit as the red light still glows, brilliant light fills the sky as flares explode off the sides of your aircraft in response to a surface-to-air threat that’s engaged the C-130’s anti-aircraft defenses. In this moment of what might otherwise be characterized as sheer terror, all you can do is laugh and yell “freaking* hell yes” as your teammates look at you in horror. Moments later the green exit light illuminates the path to two months in the Iraqi combat theater, the second country I’ve fought in at that point in less than one year. I’ve seen helicopters shot down, been stuck in a linear ambush as vehicles are blown off the road around me, watched tracers ascend around me like rain turned upside down while strapped to the side of a small helicopter, been surrounded by the enemy…but none of these stories are unique to me…they‘re similar to those shared by many combat veterans…

November 15, 2019

I have felt FEAR…pure unadulterated fear. I remember it like it was yesterday as we received indirect fire on Haditha Dam in Iraq. It was without question the only time I felt fear like that in Afghanistan or Iraq. Although over in a moment, I still remember the bone chilling feeling of that night. A deployment later, I felt the impact of TRAUMA as I watched mortars fall around me from a rooftop instead of seeking shelter as my base came under attack. I didn’t feel fear…I didn’t feel anything. PTSD (post-traumatic stress disorder) is mental health problem that some people develop after experiencing or witnessing a life-threatening event, like combat, a natural disaster, a car accident, or sexual assault. It’s normal to have upsetting memories, feel on edge, or have trouble sleeping after this type of event. At first, it may be hard to do normal daily activities, like go to work, school, or spend time with people you care about. But most people start to feel better after weeks or months. If it’s been longer and you’re still having symptoms, you have PTSD. For some people, PTSD symptoms start later, or they may come and go over time. We’ll discuss more about PTSD signs, symptoms, treatment and your role in the next few posts.

November 22, 2019

Veteran’s Day +1. I spoke about my service and PTSD for the first time yesterday. I was hesitant but it was requested. After the speech I had countless veterans and family members of veterans saying “thank you” and “I needed to hear that.” Who do you know that may be suffering from PTSD? Let’s pick up where we left off… Symptoms. PTSD symptoms can be delayed or manifest immediately. They include: 1. Reliving the event – often referred to as a ‘flashback,’ this symptom is often triggered by an outside source. Sources can be sights, smells, hearing a sound, or reading something. This symptom also manifests through nightmares. 2. Avoidance – where individuals avoid people or situations that remind them of the event. Crowded places and public transportation can be very difficult. 3. Negative thoughts and feelings – notably more than before the event. Lacking positive emotions, guilt, feeling sad or numb, and losing interest in people or activities that were previously enjoyed. 4. Feeling on edge – which makes it hard to relax and can lead to hyperarousal, anger and irritability. May manifest through unhealthy actions like abusing alcohol or aggressive driving. We’ll discuss diagnosis, treatment and how symptoms act as barriers in the next post.

October 27, 2019
Come Visit Kairos at the HR Southwest Conference

Kairos Services is ready to talk Affirmative Action compliance. Come see us at the HR Southwest Conference in Forth Worth!

October 02, 2019
Disability Self-Identification Initiatives

DISABILITY SELF-IDENTIFICATION INITIATIVES – We hear about them all the time, often how they’ve achieved less than desirable results. It’s true, industry, job type, geography, culture, etc., they’re all factors that influence self-identification. HOWEVER, “initiative” derived from the Latin ‘initium’, means ‘a beginning’.

I often ask the question, “What do you do in the beginning?” What specifically do you say to new hires about disability? Do you explain the ADA’s three part definition? Do you show employees a more extensive list of disabilities beyond the few included in Form CC-305? Most importantly, do you DISCUSS disability? How can an employee be expected to self-identity if they don’t understand the definition of disability and its application in the workplace?

Nearly all Federal contractors include all or part of their EO policy and form CC-305 in onboarding materials but few meaningfully discuss disability. Training leads to discussion – discussion leads to understanding – understanding yields results.

It only takes a few minutes to define and explain disability to your employees. Do this in the beginning, train it at least annually, and you‘ll see significant results in disability awareness and self-identification rates.

Nicolas Paul
Director of Compliance – Kairos

September 12, 2019
EEOC Not Seeking Renewal of EEO-1 Component 2

Today, the EEOC published a Notice of Information Collection regarding the EEO-1 in the Federal Register. Notably missing from the notice was a request to renew the authorization to collect Component 2 (pay & hours) data. While they requested renewed authorization to collect Component 1 (race & gender) data as their authorization expires at the end of the month, they noted that their revised burden analysis filed earlier this week shows Component 2’s “unproven utility” is far outweighed by the burden imposed on employers with the reporting obligation. (The actual analysis showed more than a 1000% increase in burden estimate, from $53.5 million per year to over $600 million per year.) The EEOC concludes it needs to first study the ongoing Component 2 data collection before deciding whether to submit for a renewed authorization request to the OMB.

IMPORTANT NOTE – Employers currently subject to EEO-1 Component 2 are still required to submit 2017 and 2018 pay data by September 30, 2019. 

https://www.govinfo.gov/content/pkg/FR-2019-09-12/pdf/2019-19767.pdf

https://www.eeoc.gov/eeoc/newsroom/wysk/eeo-1-notice.cfm

September 04, 2019
Announcing Section 503 Focused R

The Office of Federal Contract Compliance Programs (OFCCP) is dedicated to promoting disability inclusion in the workplace. With the launch of Section 503 Focused Reviews this fall, OFCCP has released compliance assistance resources to help employers and workers to better understand the law and how the reviews will be conducted.

To help contractors prepare for Section 503 Focused Reviews, OFCCP will be hosting a webinar discussing the scheduling process, the focused review process, common problem areas, and best practices. During the webinar, contractors will have the opportunity to ask questions and will be provided helpful information and resources available to assist them in increasing the employment of individuals with disabilities.

Details for the Section 503 Focused Reviews webinar follow:

Contractors who are unable to join us for the webinars will be able to watch the recordings on the Section 503 Focused Review webpage.

September 03, 2019
OFCCP Ramping Up Closure Rates

OFCCP’s latest closure data shows closures up 300%+ Year-Over-Year in July for 3 regions.  Three additional regions experienced a drop of 84% Year-Over-Year – a nationwide 100% increase (no data yet on August).  Kairos expects this increase in closures to continue if OFCCP is to ramp up to 3,500 evaluations+ per year. In total the agency has closed 875 compliance evaluations through July for FY 2019.  Visit our Enforcement Trends Tool to learn more!

August 26, 2019
West Texas HR Symposium Recap

Last week Kairos employees attended the inaugural 2019 West Texas HR Symposium in Lubbock, Texas.  The Symposium, hosted in partnership with Texas Business Conferences & Texas Workforce Commission, was Co-Hosted by the West Texas SHRM Chapters.  Thanks to excellent cooperation between these organizations and agencies, the conference was well attended and received excellent feedback from attendees.  Nick Paul and James Teeling would like to thank all attendees that stopped by and spoke with Kairos about Affirmative Action and EEO Compliance.  We look forward to seeing you next year!

August 19, 2019
Vets-4212 Reporting Deadline – September 30

The deadline will be here before you know it!

In a compliance audit with OFCCP, you will be asked to provide copies of your reports so be sure you save a copy of your submission.  Federal contractors are required to file Vets-4212 reports if they meet the requirements detailed below.

August 09, 2019
Marcus Stergio Appointed as OFCCP Ombudsman

The U.S. Department of Labor just announced the appointment of Marcus Stergio as OFCCP’s Ombudsman. Originally announced by directive in September 2018 (DIR 2018-09), OFCCP’s Ombud Service will provide an impartial and independent perspective to enhance communication between OFCCP and external stakeholders.

“The Ombud Service fits squarely within the Office of Federal Contract Compliance Programs’ broader initiative to improve transparency in our compliance evaluation and compliance assistance activities,” said OFCCP Director Craig E. Leen.

Marcus previously served as the primary administrator of the dispute resolution process for a number of multi-national organizations and institutions.  He received his Master’s degree in conflict resolution from the University of Massachusetts, Boston and his Bachelor’s degree from Northeastern University.

Marcus’ first assignment will be to design and implement OFCCP’s Ombud Service to facilitate fair and equitable resolutions for issues raised by OFCCP stakeholders in coordination with agency offices.

August 05, 2019
Excel Training for HR Professionals

Kairos is proud to launch our Excel Training for HR Professionals workshop. This workshop will teach your team to master some of Excel’s most powerful features, saving you countless hours collecting, reconciling and utilizing your HRIS and ATS data. Visit www.KairosServicesInc.com for more information or call us at 972-369-0015.

August 02, 2019
2019 National ILG Conference Recap

Highlights from OFCCP Director Craig Leen’s Comments

OFCCP Director Leen provided insight into the agency’s current and future direction at the 2019 National Industry Liaison Group Conference, detailing plans extending as far as three years.  In his opening remarks to a packed auditorium in Milwaukee, Director Leen stated:

“If you remember one thing from my speech, remember this. It’s time in this country that we treat people with disabilities the same way we treat people based on gender or race or other areas that we protect, that they’re able to be fully included in employment to the same extent as every American.  That’s something that needs to be a fundamental principle of what we do at this agency.  What the EEOC does and what we do across the country…It’s the focus of OFCCP this year.”

Even if you’re not on the current Section 503 Focused Review list, all types of OFCCP compliance audits are expected to vastly increase in the next two years, with OFCCP seeking to double and even triple the number of reviews. Elaborating further, Director Leen stated:

“I believe we can make an impact for individuals with disabilities similar to the impact this agency has made with race and gender issues; in compensation, hiring, and promotions, and I feel it is time that the agency goes there, and I believe this is something that will continue across administrations.”

Now more than ever, seamless compliance is of the utmost importance as it relates to individuals with disabilities and protected veterans.  Without question, individuals with disabilities are the Director’s primary focus, with increasing attention being paid to compensation differences and promotional opportunities. We strongly encourage Federal contractors to visit OFCCP’s Section 503 Focused Review Landing Page.  Director Leen outlined the following best practices related to Section 503:

  • Maintain a centralized reasonable accommodation system
  • Utilize accessible online recruiting tools
  • Obtain senior leadership support, including correspondence and videos (if possible)
  • Coordinate with state and local vocational rehabilitation agencies
  • Create a comprehensive and welcoming self-identification program
  • Create a disability inclusion program
  • Create and utilize employee resource groups
  • Appoint a Chief Accessibility Officer

OFCCP uploaded a “Best Practices for Creating an Inclusive Workplace” document with more detail that can be accessed by clicking here.

July 01, 2019
NORC EEO-1 Component 2 Website is Live

The National Opinion Research Center (NORC) opened their EEO-1 Component 2 website yesterday, providing information and instructions to Federal contractors for their 2017 and 2018 filings.  Based on Kairos’ initial assessment, the information contained on the site is consistent with the original Component 2 submission requirements previously published by EEOC.

You can access the website and FAQs at https://eeoccomp2.norc.org/info.html. If you have any questions, please reach out.

June 17, 2019
EEO-1 Component 2

If Kairos currently files your EEO-1 reports, we will send custom templates for each year identifying what data to pull. If you want Kairos to file your Component 2 report, please reach out for a quote.

Kairos has been keeping a close eye on news related to EEO-1 Component 2. The latest update provided by EEOC to Judge Tanya Chutkan included the following timeline:

  • June 17, 2019 – Help Desk scheduled to open
  • June 30, 2019 – FAQs posted to website
  • Early July 2019 – EEOC will contact employers by mail and email without log-in information
  • Mid July 2019 – EEOC will contact employers by mail and email with log-in information
  • July 15, 2019 – Manual Component 2 entry will open
  • Early August 2019 – Reminders will be sent via mail and email
  • August 15, 2019 – Data file Component 2 upload entry will be available

The EEOC has contracted with NORC, the non-partisan and objective research organization at the University of Chicago, to collect the EEO-1 Component 2 data. The portal for filing will not be through the traditional EEO-1 link, rather through a NORC portal at https://eeoccomp2.norc.org/.

The EEOC will be collecting two years of pay data covering 2017 and 2018. It will be filed as two separate reports. Based on the criteria originally published in 2016 the filing requirements are:

  1. Private employers including federal contractors and subcontractors with 100 or more employees will submit Component 1 and Component 2
  2. Federal contractors and subcontractors with 50-99 employees will complete only Component 1

What will be reported?

We expect the report for each establishment to include the following:

  • Number of Employees (for 2017 and for 2018) – Using W-2 Box 1 pay data you will report the number of employees by race and gender in 12 pay bands for the 10 EEO-1 categories

Figure 1: Example of Number of Employees reported for EEO-1 category 1.1 by race/gender

  • Hours Worked (for 2017 and 2018) – Add all work hours for each employee by race and gender in 12 pay bands for the 10 EEO-1 categories.
    • Salaried Workers – provide actual hours if available, if not you can assume 2080 for full-time and 1040 for part-time
    • Hourly Workers – actual hours worked

Figure 2: Example of Hours Worked by Employees reported for EEO-1 category 1.1 by race/gender

What do you need to get ready to file?

While the actual portal and requirements haven’t been updated, Kairos recommends preparing the following:

  • Your 2017 and 2018 data file used to prepare your 2017 and 2018 EEO-1 reports. This should have Employee IDs for individuals reported as well as the EEO-1 category filed.
  • For the employees in those two files gather the following:
    • W-2 Box 1 wages
    • Number of hours worked during the W-2 period
    • Date of hire
    • Date of termination
    • Exempt/Non-Exempt status
    • Full/Part-Time status

————

For questions please reach out to Jennifer McAlister, Director of Operations at 972-369-0015.

May 03, 2019
EEO-1 Survey: What We Know

As most of you are aware, a U.S. District Judge mandated the EEOC reinstate the compensation and hours worked portions of the EEO-1 Report, referred to as Component 2 “Pay Data,” resulting from a lawsuit filed against the OMB. Over the past couple of weeks Kairos has been monitoring EEOC’s website for concrete information regarding the collection of Component 2 pay data. An announcement was supposed to be posted on their website on April 29, as well as an email notifying each filing official for companies that file EEO-1 reports annually.

The unknown
This is a fluid situation and the EEOC has not released the format of the final Component 2 submission. If the Joint Reporting Committee stays true to what was originally proposed, companies will be reporting W-2 wages and hours worked.

Kairos is keeping an eye out for information directly from the Joint Reporting Committee. We have been reading and seeing lots of speculation. As soon concrete information is released from EEOC, we will notify you so you can be prepared.

There is a to-be-published document, dated May 3, on the Federal Register stating they will be collecting pay data for 2017 and 2018 by September 30, but it does not list any format or content specifics.

The known
The 2018 EEO-1 portal is now open to file your Component 1 Data. This is the standard report filed annually which currently does not require Component 2 (pay data and hours worked). The deadline to file is May 31, 2019.

April 03, 2019
BREAKING NEWS: EEOC Informs Court that it is Able to Undertake and Close Collection of 2018 EEO-1 Component 2 Data by September 30, 2019

Last month Kairos reported the U.S. District Court for the District of Columbia vacated the 2017 stay which delayed the implementation of EEOC’s pay data collection and indicated “the previous approval of the revised EEO-1 form shall be in effect.” At that time, Judge Tanya S. Chutkan issued a deadline to EEOC to inform employers whether submission of employer pay data would be forthcoming. See Mem. Op. at 40-41, ECF No. 45 (Mar. 4, 2019). EEOC met the court’s April 3 deadline, confirming they are “able to undertake and close the collection of 2018 EEO-1 Component 2 data by September 30, 2019.” See Case 1:17-cv-02458-TSC Document 54 Filed 04/03/19.

Component 1 Data Due May 31, 2019

The 2018 EEO-1 portal is now open to file your Component 1 Data. This is the standard report filed annually which currently does not require Component 2 EEO-1 pay data. The window for filing is March 18 – May 31, 2019.

The contact listed on the prior year’s report should have received an email last week from the Joint Reporting Committee with information to obtain this year’s password. If your EEO-1 contact person has changed, you must submit a letter on company letterhead signed by an authorized company representative, indicating the EEO-1 company number, new contact’s name, title, phone number and email address to the Employer Data Team at e1.lostloginpassword@eeoc.gov. We recommend you do this as soon as possible to avoid unnecessary delays in the submission process.

Component 2 Data Pay Data Due September 30, 2019?

IF EEOC can meet their self-imposed deadline, pay data will be due September 30, 2019.  It’s important to note that EEOC will use a contractor to collect compensation data from employers separate from the traditional EEO-1 Report – EEOC’s reporting system is not currently structured to handle the additional data.  The plaintiffs have until April 8 to respond to the EEOC’s stated plans for pay data collection. Numerous employer organizations, including the U.S. Chamber of Commerce, have submitted friend-of-the-court briefs asserting that any pay data collection should occur in 12-18 months, at the earliest.

Kairos will continue to provide Component 2  filing information as it becomes available.

March 26, 2019
OFCCP Releases List of 3,500 Establishments to be Audited

OFCCP just released the long-awaited Corporate Scheduling Announcement List (CSAL) in the OFCCP Freedom of Information Act (FOIA) Library.  Unlike previous CSAL announcements, this list was posted only in the online FOIA Library without mailing advanced contractor notifications to individual establishments. CSALs notify establishments that they will undergo a compliance audit (likely in the current scheduling cycle).

If you’re on the list: OFCCP will not begin scheduling audits for 45‐days from today (as early as May 9th). After receiving the scheduling letter and itemized listing, you will have 30 days to submit your Affirmative Action Program (AAP). If your AAP is submitted by the initial 30-day deadline and need more time to submit supporting data, OFCCP will grant a one‐time 30‐day extension for supporting data. Contact Kairos to begin preparing as soon as possible.

Kairos prepared the following summary list of review types from the data released by OFCCP today.  The scheduling list can be viewed by clicking here.

Review Type Total
Establishment Review 2,345
503-Focus Review 500
Compliance Check 500
CMCE Review 83
FAAP Review 72
Grand Total 3,500

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To read more information about Section 503-Focused reviews, click here.
To learn more about what you can do to prepare for a new 503 “Disability focused” audit, click here.

OFCCP is aggressively enforcing compliance with veterans and individuals with disabilities regulations as well as increasing their focus on hiring and compensation disparities.  Ensure proper data collection and recordkeeping systems are in place and all required positions are being listed with local State Employment Services.

We are currently reviewing the scheduling list. If we find your establishment on the list you will receive an e-mail and follow-up call to notify you of the CSAL and your next steps.

March 18, 2019
2018 EEO-1 Portal Open for Component 1 Data

The 2018 EEO-1 portal is now open to file your Component 1 Data. This is the standard report filed annually which currently does not require Component 2 EEO-1 pay data. The window for filing is March 18 – May 31, 2019.

The contact listed on the prior year’s report should have received an email last week from the Joint Reporting Committee with information to obtain this year’s password. If your EEO-1 contact person has changed, you must submit a letter on company letterhead signed by an authorized company representative, indicating the EEO-1 company number, new contact’s name, title, phone number and email address to the Employer Data Team at e1.lostloginpassword@eeoc.gov. We recommend you do this as soon as possible to avoid unnecessary delays in the submission process.

Early this morning the EEOC released their first acknowledgement of the court order to reinstate the Component 2 EEO-1 pay data. They are currently working on steps for the collection of data and will provide information as soon as possible.

March 12, 2019
Corporate HQ’s to be scheduled for Disability Focused Audits

Just last week, OFCCP released its scheduling letter for Section 503 (Disability) Focused Reviews, providing new procedural details to Federal contractors. This first round of Focused Reviews will include on-site reviews of only CORPORATE HEADQUARTER locations. 

Review this checklist to see how prepared you are:

  • Are you ready for OFCCP to conduct onsite interviews with managers responsible for EEO and ADA issues? Have you formally appointed and trained an employee to handle these matters?
  • Do you have written policies and procedures for handling reasonable accommodation requests? This is a best practice that goes a long way toward compliance.
  • Are your managers trained to handle requests from employees?
  • Are you documenting accommodation requests and their final disposition?
  • Are you properly engaging employees in the interactive process?
  • Have you done outreach with organizations that target individuals with disabilities? If not, start by reviewing OFCCP’s list of organizations (page 2 of the PDF).
  • Have you put any of OFCCP’s Best Practices in place for creating an inclusive workforce?
  • Have you completed your required annual assessment of your outreach and recruitment efforts, evaluating each effort separately and identifying new efforts for the coming year? Check out our template at our Client Portal (included in the Veteran and Disability Regulations Self-Assessment Toolkits).
  • Have you conducted your required annual self-audit for Section 503? Check out the template available on our Client Portal in the same toolkit mentioned in the previous bullet.

For more information, visit OFCCP’s new FAQs and portal. For questions, contact us by phone or e-mail, we’re here to help you achieve compliance.

March 05, 2019
BREAKING NEWS: EEO-1 Pay Data Reporting is Back – Immediately!

Yesterday the U.S. District Court for the District of Columbia vacated the 2017 stay which had delayed the implementation of EEOC’s pay data collection and indicated “the previous approval of the revised EEO-1 form shall be in effect.” The EEO-1 portal is currently scheduled to open March 18, 2019. It is unknown whether this decision will impact the impending reporting period, or whether the government will seek to appeal this decision.

Notably, the judge stated this “will not have potentially disruptive consequences” for filers because the “revised pay data collection had been in place for almost a year by the time it was stayed” and the stay was only temporary. In other words, filers knew this was coming, so they should not need any extra time to comply. This could add quite an unfortunate twist to this reporting period, so stay tuned!

Civil Action No. 17-cv-2458 (TSC) – MEMORANDUM OPINION: Regarding Defendants’ Motion to Dismiss 11, Plaintiffs’ Motion for Summary Judgment 22, and Defendants’ Motion for Summary Judgment 27. Signed by Judge Tanya S. Chutkan on 3/4/2019.

Feb 05, 2019
250% Increase in Your Chances of an OFCCP Audit?

OFCCP plans to go from scheduling under 1,000 compliance audits in 2018 to a whopping 3,500 in 2019. While this goal may seem lofty given its dwindling workforce, OFCCP intends to increase audits by conducting more abbreviated reviews. They rescinded the Active Case Enforcement Directive requiring “full audits” and are adding “Focused Reviews” in 2019.

What are Focused Reviews?
This administration wants to increase its focus on those other two AAPs that in most compliance audits are all-but forgotten: Individuals with Disabilities and Protected Veterans (IWDs and PVs). These new audits will focus primarily on these AAPs and their actual implementation, though they are expected to include at least a cursory review of the EO 11246 AAP as well. They will include MANDATORY ONSITES.

I have limited time! How can I best be prepared?
Here is what we recommend, in order:

  1. Get your AAP prepared timely! Common delays stem from having to compile information from multiple data sources, especially applicant flow data tracking systems– review your system and test your ability to pull the data in advance of the deadline to work out any issues.
  2. Fill out the self-audit forms for IWD and PV, which are available on the client portal. This is required annually.
  3. Evaluate your outreach efforts each year … in writing! (again – available on our client portal).
  4. Ensure you are listing and documenting all externally filled positions with the State Employment Service. This is a minimum requirement – it does not fulfill your requirement to conduct outreach if you have goals or are below the veteran hiring benchmark.

Go above & beyond in outreach as far as making efforts, tracking, and evaluating. OFCCP can easily determine whether you have an active commitment to affirmative action and participate in outreach programs.

For more details reach out to Kairos today!

Feb 01, 2019
Change in 2018 EEO-1 Survey Launch and Deadline

The EEO-1 website was updated over night. The opening of the website for filing 2018 EEO-1 reports has been delayed until early March 2019. The deadline for filing has also been extended to May 31, 2019.

Before the online system opens the EEOC Joint Reporting Committee will send instructions via email to the contact listed on last year’s EEO-1 Reports. If you have any changes in contacts, company names, purchases or spin-offs now is the time to report those so you don’t have any delay once the system opens.

Kairos offers EEO-1 report preparation and filing services. If you would like us to submit your reports please email or call us for a quote today.

January 08, 2019
Veteran and Disability Unemployment Rates – December 2018

Veteran and disability unemployment have seen an overall decreased from December 2017 to December 2018, with a slight increase in the last two months of 2018.

You can view more detailed information about other employment statistics at the Bureau of Labor and Statistic’s Economic News Release website page.

January 01, 2019
Kairos Launches Compensation Analysis Reports

Tucked away in OFCCP’s regulations, “Additional required elements of affirmative action programs,” is one weighty requirement: “The contractor must evaluate: Compensation system(s) to determine whether there are gender-, race-, or ethnicity-based disparities.” (41 CFR § 60-2.17(b)(3)) In recent years, OFCCP has committed considerable resources into enforcement of this requirement by hiring a team of highly-skilled statisticians and labor economists, which can be intimidating to even the largest of contractors. Those efforts have produced results in the way of significantly larger settlements for compensation discrimination. Compounding the difficulty to comply with this regulation, OFCCP does not provide the criteria it uses in the desk audit to flag compensation for regression by a statistician. While OFCCP recently released some details of its process for conducting compensation reviews, they were hardly a road-map for an initial[1] analysis (the Directive listed some technical explanations of the ways OFCCP runs a regression analysis[2].)

The Problem

How can contractors run an analysis similar to OFCCP’s initial desk audit compensation analysis and work to resolve indicators prior to an audit to reduce the chance OFCCP will need to run regression analyses if OFCCP does not release its initial analysis methodology?

Our Solution

Kairos is launching a new Compensation Analysis Report designed to provide your company with the indicators OFCCP would calculate in a desk audit. Designed by our former OFCCP Compliance Officer, the reports highlight any significant differences that exist by job group, job title, and any other pay analysis group (as needed).

Compensation can seem too complex to tackle – it is complex. That’s why OFCCP leaves those analyses to PhD-level statisticians when initial desk audits show significant indicators. Kairos’ goal with these analyses is to help your company avoid getting to that point! Take the first step toward compliance today by reaching out to Kairos staff for more information, pricing, and sample compensation reports.

[1] The analysis a compliance officer conducts in the desk audit used to determine the need for further analysis.

[2] A statistical technique in which more than one variable (e.g. tenure, education, department) is used to predict compensation.

December 03, 2018
One Month Until the 2018 EEO-1 Survey Launch

Companies are now only four weeks away from the start of the 2018 EEO-1 Survey filing window. Federal contractors are required to file EEO-1 reports if they meet the requirements. In the event of an OFCCP audit you should expect to be asked to provide copies of your reports – so be sure you download or print a copy of your final certified reports. Also remember the closer to the deadline you file the more likely the agency will be unavailable to assist you with technical issues in time to file by the deadline.

If you would like Kairos to review your reports and compare them to your AAPs for consistency please let us know before the end of December. Kairos also offers EEO-1 report preparation and filing services.  If you would like us to submit your reports please email or call us for a quote today.

The Vets-4212 Report deadline was September 30.  As of this morning, December 3, the system is still open if you haven’t yet filed your reports.

November 06, 2018
Veteran’s Day 2018

This Veteran’s Day we honor the men and women who have served in the United States Armed Forces. 

Our way of life could not exist without the scars you bear – the price you’ve paid for our freedom.

This Veteran’s Day, Kairos encourages you to honor the service of veterans in your workforce and community.  For additional outreach and inclusion resources and suggestions please contact our office at 972-369-0015.

Veteran’s Day 2018: Sunday, November 11

Observed Date: Monday, November 12

October 24, 2018
2018 EEO-1 Survey

What a busy time of year! Vets-4212 annual reports were due by September 30, 2018. As of this morning, the system is still open if you haven’t yet filed your reports.

Now is the time for companies to prepare for the 2018 EEO-1 Survey. Once the survey is open in January 2019 an email will be sent to the email address indicated as the EEO-1 Report Contact on the prior year report. If the person previously listed on the form is no longer with the company you will need to submit a change request. Also, if you company has experienced any mergers, acquisitions or spin-offs now is the time to submit those changes.

Who is required to file?
All companies that meet the following criteria are required to file the EEO-1 Survey report annually:

  1. Subject to Title VII of the Civil Rights Act of 1964, as amended, with 100 or more employees; or
  2. Subject to Title VII of the Civil Rights Act of 1964, as amended, with fewer than 100 employees if the company is owned by or corporately affiliated with another company and the entire enterprise employs a total of 100 or more employees; or
  3. Federal government prime contractors or first-tier subcontractors subject to Executive Order 11246,as amended, with 50 or more employees and a prime contract or first-tier subcontract amounting to $50,000 or more.

When do you file?

  • Companies need to pull an employee snapshot from one pay period between October 1 – December 31, 2018. Kairos recommends pulling the data now so you have ample time for review before filing.
  • Companies must submit and certify their reports online between January 1 – March 31, 2019.

Need some help?
If you are interested Kairos can prepare your EEO-1 Survey reports for you. Call or email us with questions or for pricing information.

June 19, 2018
Jennifer McAlister Presenting at the 2018 ILG National Conference in Anaheim, California

Kairos Services, Inc. is pleased to announce that Jennifer McAlister, Director of Operations, will be presenting at the Industry Liaison Group (ILG) National Conference in Anaheim, California from July 30 – August 3.  Please see Jennifer’s presentation title and description below.

“The Next Step Towards Becoming a Data Wizard”

You pulled data from the HRIS and Applicant Tracking System. What now? Ensuring your data’s integrity is a crucial step in preparing your AAP. Do you want to learn some techniques for ensuring all hires are on the Applicant Flow Log? In a pickle because you aren’t able to pull accurate promotion data? Do you have repetitive data formatting, merging, or cleanup tasks you’d like to automate? We’ll demonstrate some examples with Excel’s Power Query tool, PivotTables, Vlookup, and other formulas that will make copy/paste seem primitive. Impress your peers and manager while saving yourself time and headaches by upgrading your data skills!

The annual ILG National Conference is dedicated to training and assisting Federal contractors who are required to comply with various regulations enforced by the Office of Federal Contract Compliance Programs (OFCCP) and Equal Employment Opportunity Commission (EEOC).  If you’re interested in attending this year’s conference please visit http://ilgconference.com/2018/ for more information and to view the agenda

June 05, 2018
Nicolas Paul Presenting at the 2018 ILG National Conference in Anaheim, California

Kairos Services, Inc. is pleased to announce that Nicolas Paul, Director of Compliance, will be presenting at the Industry Liaison Group (ILG) National Conference in Anaheim, California from July 30 – August 3.  Nicolas is a frequent presenter at local, regional and national ILG conferences and is the President of the North Texas ILG.

The annual ILG National Conference is dedicated to training and assisting Federal contractors who are required to comply with various regulations enforced by the Office of Federal Contract Compliance Programs (OFCCP) and Equal Employment Opportunity Commission (EEOC).  If you’re interested in attending this year’s conference please visit http://ilgconference.com/2018/ for more information and to view the agenda.

May 18, 2018
OFCCP extends 2014 TRICARE Enforcement Moratorium

The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) today issued a two-year extension of its enforcement moratorium relating to the affirmative obligations of TRICARE providers. This moratorium has been in effect for four years, and will now expire on May 7, 2021; it will also now apply to Veterans Affairs Health Benefits Program providers.

“By providing greater regulatory certainty to TRICARE providers and Veterans Affairs Health Benefits Program providers, the Administration can help ensure that America’s veterans and their families can access quality health care,” said OFCCP Director Ondray T. Harris.

Read more at https://www.dol.gov/newsroom/releases/ofccp/ofccp20180518.

May 17, 2018
Kairos Executive to Lead North Texas Industry Liaison Group (ILG)

Kairos is pleased to announce that our Director of Compliance, Nick Paul, will be leading the North Texas Industry Liaison Group as President for 2018-2019. Other officers who will be installed at the next meeting include:

○ Vice President – Mark Nagel (Southwest Airlines)
○ Secretary – LaShanda Reed-Larry (Essilor)
○ Treasurer – Brenda Sitton (Nokia)

Dr Pepper Snapple Group is hosting the May 17 meeting in Plano from 1:00 – 4:00 p.m. Presenters for the meeting will be Southwest and Rocky Mountain (SWARM) OFCCP Regional Director Melissa Speer and Patrick McNeil of PeopleFluent.

May 01, 2018
OFCCP’s Methodology for Developing the Scheduling List

Under the leadership of Ondray T. Harris, OFCCP recently released a detailed description of the methodology used for developing their scheduling list of supply and service federal contractors. This process has been summarized in the article below. OFCCP’s audit selection process starts with the agency downloading Federal contract information from archived files of the Federal Procurement Data System–Next Generation (FPDS-NG) for three preceding years (2015, 2016 and 2017). The FPDS is a database of federal contracts maintained by the U.S. General Services Administration (GSA) that identifies contracting bodies, contractors, the value and term of federal contracts, as well as other relevant information.

After a process of removing contractors for various jurisdictionally disqualifying factors, the agency created “Establishment Records” based on physical addresses for single establishment contractors. For contractors with more than one contract at the same physical address, the contract record with the farthest expiration date became the Establishment Record and all contract numbers from other contract records were added to it. These establishments were called “Direct Establishments.” Contract information was then matched and consolidated with the EEO-1 Database to establish a “Parent Record” for single and multi-establishment contractors with one or more contracts. For each parent in the Parent File, OFCCP extracted all establishments with 100 or more employees from the EEO-1 database and added them to the Establishment File. These extracted establishments did not have direct contracts but fell within OFCCP’s jurisdiction because their parent entity had a covered direct contract(s). These additional establishments were called “Associate Establishments.” OFCCP then added contract information from the parent record to the respective Associate Establishment records.

After the reduction and consolidation processes summarized above, the remaining records created the “Available Pool” for selection. When all establishments in the Available Pool were identified, they were randomly ordered and uploaded to OFCCP’s Case Management System for processing by its district offices. OFCCP does not purge unscheduled cases from prior lists before releasing the new scheduling lists.

If you would like to review OFCCP’s full published methodology, please click here to download the file.

Feb 26, 2018
EEO-1 Filing Season has Arrived

The 2017 EEO-1 Survey online filing system is now open for business and the March 31, 2018 deadline will be here before we know it. Website changes made by the Joint Reporting Commission (JRC), the organization responsible for collecting EEO-1 Reports, include additional security protocols. The JRC has published an EEO-1 Survey User Guide with helpful information and step-by-step instructions.

Federal contractors are required to file EEO-1 reports if they meet certain thresholds. In the event of an OFCCP audit you should expect to be asked to provide copies of your reports; so be sure you download or print a copy of your final certified reports. Also remember the closer you file to the deadline the more likely technical issues will arise and the agency will be unavailable to assist you in time to file by the deadline.

If the person previously listed on the EEO-1 Reports is no longer with the company you will need to submit to the EEOC a signed change request on company letterhead with the company number, name, title, phone number and email address of the new contact person at your company. This change request MUST be signed by an authorized company representative in order for the change request to be processed. Please either scan or email this request to e1.techassistance@eeoc.gov or fax to 1-866-262-0032. Your new contact will receive an email directing you to create your new password once your change request has been submitted.

If you would like us to review your reports and compare them to your AAPs for consistency please let us know as soon as possible. Kairos Services also offers EEO-1 report preparation and filing services. If you would like us to submit your reports this year please email or call us for a quote today.

Feb 26, 2018
Announcement – New Employee Will Waymel

Kairos is pleased to announce the addition of Will Waymel as a Senior Compliance Specialist. Will brings to Kairos eight years of experience as a Compliance Officer in the Office of Federal Contract Compliance Programs (OFCCP) Denver District Office. As an OFCCP Compliance Officer, Will audited companies for compliance with Affirmative Action regulations, analyzed compensation data and reviewed personnel records and Affirmative Action Plans. During his tenure at OFCCP, Will trained employees from the Southwest and Rocky Mountain Region (SWARM) on advanced Microsoft Excel functionality and custom VBA macros to increase data management efficiency. Prior to his time with OFCCP, Will was a Budget & Recruitment Manager for the Metropolitan State University of Colorado in Denver.

Will’s primary focus is to provide Kairos clients with audit services, compensation analyses, AAP preparation and training services. He will be available by phone and email to respond to questions along with the rest of the Kairos team. Will can be reached at the main office 972-369-0015 or directly at 720-515-0870.

Will, who is bilingual (Spanish), holds a Bachelor’s degree from the University of Colorado at Boulder and two Master’s degrees from the University of Colorado Denver – one in Business Administration and the second in International Business. Will, his wife Alissa and their five children (with a sixth on the way) returned in mid-December to the United States from a year-long mission trip in the Greek-speaking island of Cypress.

August 29, 2017
Preparing For Your 2017 Vets-4212 Filing

The VETS-4212 reporting deadline will be here before you know it. Federal contractors are required to file VETS-4212 reports if they meet the requirements. In the event of an OFCCP audit you should expect to be asked to provide copies of your reports.

Who is required to file? All nonexempt Federal contractors and subcontractors with a contract or subcontract in the amount of $150,000 or more with any department or agency of the United States for the procurement of personal property or non-personal services.

When do you file? Once the VETS-4212 online system is open, usually July, through September 30.

Need some help? We can review your reports and compare them to your AAP for consistency in reporting. If you are interested we can also prepare your VETS-4212 Reports for you. Just email me with questions and prices.

July 11, 2017
Breaking News: EEO-1 Pay Data Reporting Indefinitely Postponed

On August 29 the Office of Management and Budget (OMB) indefinitely postponed the pay data collection aspects (Component 2) of the EEO-1 form that was revised on September 29, 2016. The previously approved EEO-1 form which collects data on race/ethnicity and gender by occupational category will remain in effect.

What does this mean?

  • Contractors will not be filing an EEO-1 report in 2017.
  • Contractors will need to pull a workforce snapshot for a pay period between October 1 and December 31.
  • Contractors will file EEO-1 between January 1 and March 31, 2018.

If you have any questions please call the Kairos office at 972-369-0015.

June 29, 2017
Nick Paul Speaking at the 2017 Industry Liaison Group (ILG) National Conference

Kairos’ Director of Compliance, Nick Paul, will present at this year’s ILG National Conference held August 1-4 in San Antonio. This session is a ‘must see’ for Federal contractors who have ever struggled through the process of selecting, evaluating and implementing applicant tracking systems. See more at the following link https://www.linkedin.com/feed/update/urn:li:activity:6286191648091238400.

Apr 25, 2017
Kairos’ Project Manager, Christie Hermann, is presenting at the St. Louis ILG

On Thursday, April 27, Kairos’ Project Manager, Christie Hermann, will share her talents in “Taking Your Data Crunching Skills to the Next Level” with the St. Louis ILG. HR professionals and practitioners can enhance their capabilities to track, monitor and analyze their AAP and support data more accurately and efficiently. Techniques will be demonstrated to identify and analyze potential pay disparities before submitting your compensation data for an audit or the Equal Pay Report. The use of pivot tables will teach attendees how to find data inconsistencies and “scrub” data. The use of VLOOKUP will compare two worksheets of data, use filtering for finding small pieces of data in large data files and finding duplicates in your worksheets in seconds. The session will close with how to use mail merge for getting those recruitment and outreach letters out in short order and have documentation available for audits to reflect compliance.

Feb 1, 2017
Disability Self-ID Form Update

The Office of Management and Budget (OMB) has approved the ‘new’ Voluntary Self-Identification of Disability form (CC-305). There are no changes to this revision other than an updated expiration date of 1/31/2020. Federal Contractors should begin using the new form as soon as possible. The new form can be found in English and Spanish as well as multiple formats on the Kairos Client Portal.

It is important to remember that the Voluntary Self-Identification of Disability form (CC-305) cannot be changed or altered in any way.

If you have any questions concerning this communication please call Kairos’ office at 972-369-0015.

Jan 23, 2017

Celebrating the life of Ed Roberts, a Disability Activist

Today we celebrate the life of Ed Roberts, a Disability Activist, who would have turned 78. At the age of 14, Roberts contracted Polio which resulted in paralysis and having to spend his nights sleeping in an iron lung. Roberts not only accepted his disabilities, but he went on to build up a positive image and bright future for disabled people. Roberts went on to become the Director of the California Department of Vocational Rehabilitation, proving not only can you work with disabilities, but you can be a shining star that makes the world better for everyone.