Most large employers, including those using VetCentral, utilize an electronic “applicant tracking system” or ATS to handle all incoming job applications. For these companies, the ATS is the one and only door that applicants are supposed to enter. That is done for both practical and regulatory reasons.

On the practical side, many of these companies will receive 10,000 or more applications for employment each week. Handling that many pieces of paper in the form of faxes, letters or even e-mails would be impractical. The ATS provides a way to ensure that all of the applications get into the system in a standard format and related to the proper job opening.

Compliance with these regulations is subject to regular audits by OFCCP and by enforcement actions by OFCCP, the EEOC and the Department of Justice. The easiest way to turn a compliance audit into a full enforcement investigation is to not be able to produce a comprehensive set of records.

Large corporations depend on their ATS to maintain the records and to produce their reports. Corporate policy requires all recruitment action to be conducted through the ATS. On the official job vacancy announcement for these major companies, the ones being distributed by VetCentral, all applicants will be directed to the ATS. That is the only way the corporation can be sure that all possible candidates for the jobs are considered fairly, in accordance with the Uniform Guidelines for Employee Selection Procedures.

The rules implementing the Jobs for Veterans Act specify that job announcements must contain the following minimum information: “the type of position being filled, the qualifications for the position, the location of the position, the manner in which applications are being accepted, and the application timeframe.” That information may be contained completely in the e-mail or other communication or may be provided through a link back to the job announcement on the corporate website. For most large corporations, the “manner in which applications are being accepted” is exclusively the ATS.

The state’s obligation under the Jobs for Veterans Act is two fold: a) to provide priority referral of veterans to federal contractor jobs, and b) to make sure that those contractor jobs are made available to non-Wagner Peyser one stops and to other States. Also, according to the Federal Register, Volume 72, No. 152, federal contractor receiving over $100K in federal grant funds must post their FCJL jobs with the appropriate employment service delivery system. Such a system may include a state’s job bank in which the opening occurs or the local employment service delivery system where the opening occurs. JVA and the subsequent regulations create an affirmative responsibility for the state workforce agencies to accept job order from all contractors.

The regulations specify that an employer may submit job listings in a variety of ways: including faxing, mailing, emails or other electronic postings.

VetCentral provides employers with a report documenting the delivery of job-orders to the appropriate employment delivery system, whether that is the state job-bank and/or the appropriate local employment delivery system. VetCentral reports provide information regarding the job title, an identification number, the location and date of delivery, and method of delivery.

According to the regulations, OFCCP does not have responsibility for ensuring that the appropriate employment delivery systems provide priority referral to covered veterans. OFCCP only audits employers, not state workforce agencies. However, in the process of an OFCCP desk audit an employer may request the state workforce agency provide documentation regarding a job order and/or referrals.

Currently new regulations are being developed to help meet the existing requirement that service providers ensure priority of service for all veterans. These regulations are expected to be published prior to the end of the calendar year and may further define how service providers are to collect and make available priority referral information.

The state’s obligation under the Jobs for Veterans Act is two fold: a) to provide priority referral of veterans to federal contractor jobs, and b) to make sure that those contractor jobs are made available to non-Wagner Peyser one stops and to other States. Both of those actions can technically be done without manually entering jobs received through email, fax, or mail into the state’s job bank system. However, states may want to manually enter such job orders in order to be able to track later referrals for performance purposes. In terms of redistribution of the jobs, for those states not downloading JobCentral/VetCentral job orders, and receiving emails, and as an interim solution (until an automated download into the state job bank is available) DEA is offering a "widget" which allows any office (and any neighboring States) to view all FCJL jobs from JobCentral, so, the local offices need take no further action.

The best course of action is for your state job bank to take an automated download from JobCentral and then all the jobs will be "in the State system" without need of any State action. This will provide better customer service to your state employers (you are offering compliance) and of course to your veterans. In the end this will also help increase your performance as entered employment rates will climb.

DirectEmployers will provide free indexing, if applicable, by means of JobCentral to any non-member company requesting this action through completion of a simple online form. DirectEmployers also offers free job posting by proxy of the state system through daily job uploads into JobCentral. This process allows states to validate employers, employers to post free jobs into the state system and feed the appropriate job orders into JobCentral. JobCentral, in turn, will push corresponding job seekers back to the job order on the state system for application. Non-members federal contractors may also post free jobs into VetCentral for appropriate distribution to local veteran representatives to aid JVA compliance.

DirectEmployers Association Membership Includes:

• Unlimited job indexing to DirectEmployers
• Unlimited job indexing to Diversity Network
• Unlimited job indexing to JobCentral.com
• Unlimited job XML feed to 1000+ networking sites
• Direct portal to COMPANY career center
• COMPANY listed in Companies Area
• Association Member Voting Rights
• Participation in Monthly Think Tanks
• Participation in Annual Meeting
• Unlimited Job delivery to VetCentral (JVA - OFCCP Compliance)