National Benchmark Example I

If a contractor decides on Option 1, adopting the National Percentage of Veterans in the Civilian Labor Force (national benchmark), for establishing its hiring benchmark, the next step is to analyze their veteran applicant and hire data (41 CFR 60-300.44(k)).

The example below shows how a hypothetical contractor might assess their outreach and recruitment efforts using the national benchmark. This example is not prescriptive; it simply demonstrates a possible approach contractors may take when using the national benchmark.

World Business Company (WBC), a contractor in Portland, Oregon, decides on Option 1 and establishes its hiring benchmark by using the national benchmark of 5.5% for 2022. WBC selected the 2022 percentage based on their VEVRAA AAP date: January 1, 2023 to December 31, 2023.

According to OFCCP’s scheduling letter, WBC must provide OFCCP with documentation for the immediately preceding AAP year. (Please note that WBC is not six months or more into their current AAP year and is not subject to provide OFCCP with documentation for the first six months of the current AAP year.)

First, WBC will compare their veteran hiring percentage to the national benchmark of 5.5% for 2022.

WBC’s data collection of veteran applicant and hire data (41 CFR 60-300.44(k)).

The total number of applicants: 5,750

The total number of applicants who self-identified as a protected veteran: 178

The total number of new hires: 800

The total number of new hires who self-identified as a protected veteran: 29

National benchmark percentage as of 3/31/22: 5.5%

Veteran applicant percentage: 3.1%

Veteran hiring percentage: 3.6%

Now that WBC compared its hiring of protected veteran percentages (3.6%) to the national benchmark percentage (5.5%), according to 41 CFR 60-300.45, WBC will adopt the national benchmark because it is higher than its own hiring percentage of veterans.

Next, WBC must conduct an annual assessment of its outreach and recruiting efforts. This assessment must:

1. Evaluate the effectiveness of each outreach and recruiting effort. When evaluating the effectiveness of each effort, the contractor must document its determination and, at a minimum, it must include the criteria used to make the determination. One of the criteria that must be included is the data collected under 41 CFR 60-300.44(f)(3); and
2. Conclude whether the totality of its efforts has been effective in identifying and recruiting veterans. If the contractor concludes that the totality of its outreach and recruitment efforts were not effective, it must identify alternative efforts that it will implement to fulfill its affirmative action obligations.

Example Evaluation of WBC’s Outreach and Recruiting Efforts

WBC’s assessment for each effort provides the number of veteran applicants and the number of veterans hired. WBC used the following criteria to evaluate their outreach and recruitment efforts:

1. To what extent did the activity attract qualified applicants who are protected veterans?
2. To what extent did the activity result in the hiring of qualified protected veterans?
3. To what extent did the activity expand WBC’s outreach to protected veterans in the community?
4. To what extent did the activity increase WBC’s capacity/capability to include protected veterans in its applicant pool and workforce?

Example Evaluation of the Totality of WBC’s Efforts

WBC assesses its outreach and recruitment efforts annually. This includes an assessment of the effectiveness of each individual effort, as shown above, and an assessment of the effectiveness of the totality of our efforts for the year. If any activities are identified as ineffective, appropriate modifications will be considered accordingly.

WBC’s overall outreach and recruitment efforts are effective for the 2023 AAP. WBC has attracted a pool of veteran applicants due to participation in veteran job fairs and veteran hiring from local colleges which are listed in WBC’s VEVRAA AAP. Due to not meeting the national benchmark percentage of 5.5%, WBC will identify alternative efforts for their 2024 VEVRAA AAP. This will include contacting additional local colleges, sending additional job openings to veteran representatives, connecting with the new local veteran group WBC met at the November 13, 2022, job fair, and building an outreach relationship with the United States Army Transition Assistance Program (TAP) to gain insight on effective strategies when hiring transitioning soldiers or veterans.

Outreach and Recruitment Resources for Contractors

Contractors may engage in activities such as job fairs, recruitment activities with educational institutions, and organizations that focus on job training and development for veterans. Contractors may also develop their own outreach programs. The scope of the contractor’s efforts will depend upon circumstances, including the contractor’s size and resources, and the extent to which existing employment practices are adequate.

Below are examples of outreach and recruitment activities according to 41 CFR 60-300.44(f)(2). This is an illustrative list, and contractors may choose from these or other activities, as appropriate to their circumstances:

1. Enlisting the assistance and support of the following persons and organizations in recruiting, and developing on-the-job training opportunities for veterans, in order to fulfill its commitment to provide meaningful employment opportunities for such veterans:
   1. The Local Veterans’ Employment Representative in the local employment service office (i.e., the One-Stop) nearest the contractor’s establishment;
   2. The Department of Veterans Affairs Regional Office nearest the contractor’s establishment;
   3. The veterans’ counselors and coordinators (“Vet-Reps”) on college campuses;
   4. The service officers of the national veterans’ groups active in the area of the contractor’s establishment;
   5. Local veterans’ groups and veterans’ service centers near the contractor’s establishment;
   6. The Department of Defense Transition Assistance Program (TAP), or any subsequent program that, in whole or in part, might replace TAP; and
   7. Any organization listed in the Employer Resources section of the National Resource Directory (http://www.nationalresourcedirectory.gov/), or any future service that replaces or complements it.

For more information on the VEVRAA hiring benchmark, please visit OFCCP’s VEVRAA frequently asked questions.

Last updated on March 27, 2024