The general area is known as OFCCP compliance because the Labor Department office is called the "Office of Federal Contract Compliance Programs".

Before the rule took effect, contractors had to keep records of resumes at which they looked from online databases in the same way they did for traditional applications. That was not practical because a simple glance at a resume did not determine whether the applicant was qualified.

The rule affects about 100,000 "facilities". Monster.com estimates that 20,000 businesses representing 27 million employees would be affected by the rule.

Under the new rule, an "Internet applicant" is defined as a person who:

• Submits an expression of interest in employment through the Internet or related electronic data technology.
• Is considered by the contractor for employment in a position.
• Meets the basic qualifications for the position.
• Does not remove himself from consideration.

The rule requires contractors to change much as they did to comply with the Americans with Disabilities Act of 1990 by analyzing and writing down specific qualifications for each job. Many companies are relying on third parties, such as Monster, HotJobs.com, CareerBuilder, HodesIQ and Arbita.

One of the reasons the industry is so quiet this spring is all of the attention being paid to complying with this rule.

• Be sure to read the Labor Department FAQs on the subject.
• Here's the OFCCP Compliance Manual
• OFCCP intends to schedule far more compliance reviews in fiscal year 2006 than it scheduled in fiscal year 2005. The number of compliance reviews in fiscal year 2006 could approach 6,000, returning to the record levels of 2003 and 2004. The next wave of approximately 1,000 reviews will be sent out in the next two months.
• Organizations that believe they are not contractors may be in for a big surprise. Under its new selection system, OFCCP will determine jurisdiction through the Federal Procurement DataSystem (FPDS) to avoid jurisdiction disputes and to target enforcement efforts on organizations that failed to indicate that they were government contractors on the EEO-1 form. This means that if you sell anything to the government you might be covered by the rule.
• Most desk audits will continue to focus on statistical indicators of potential systemic discrimination, but OFCCP will also select every twenty-fifth compliance review for a full on-sitevisit.