You are probably thinking “Oh no - another article about applicant tracking codes?” I fully understand; however, I ask one simple question. How many of you are as befuddled as I am regarding the countless verbiage applied to applicant tracking codes? Disposition codes, status codes, stages, rejection reason codes. Are these terms synonymous? Each applicant tracking system (ATS) refers to the staging of candidates differently which influences which term will be used to describe either the stages/steps of the selection process or the selection outcome (disposition or rejection reason).

I conducted a Google search for applicant tracking codes and the results confirmed my suspicions about the lack of clarity in the reference to the terms disposition vs. status vs. stage. Along with the maze of applicant tracking systems, there is also an overabundance of philosophies as to the right and wrong way of dispositioning candidates. Whether you use an electronic or manual applicant tracking system, it is crucial that you:

1. Identify the various stages in the selection process, which we will refer to as either the job seeker’s status or stage; and
2. Designate the reason why a candidate is not selected or advanced to the next stage. We will refer to these as dispositions aka rejection reasons.

OFCCP’s Internet Applicant Rule clarifies who should be counted as an applicant. Only those candidates who make it through the following four steps are actually applicants for AAP analytical purposes.

1. An individual submits an expression of interest in employment by applying for a specific open position;
2. The contractor considers the individual for employment in a particular position by opening their resume and reviewing their qualifications;
3. The candidate possesses the basic qualifications for the position based on preset criteria listed in a job posting or job description; and
4. At no point prior to receiving an offer of employment does the candidate withdraw interest explicitly or implicitly (e.g. salary requirements too high, not willing to travel, accepted other offer, failed to respond to inquiries, etc.).

Assigning explanatory disposition codes will assist in determining which candidates ultimately become applicants to be counted in the impact ratio analysis on hiring activity. Lack of disposition codes or poor codes that fail to accurately articulate the rejection reason, e.g. not a good fit, will be a hindrance in determining the stage where the candidate dropped out or even if they made it through all four steps to become an applicant. Failure to disposition a candidate or assign a disposition that fails to indicate if the person meets the four prongs of the internet applicant rule will lead to an overinflated applicant pool. Having large applicant pools will affect your analyses for race and/or gender-based disparities in the hiring process.

Identifying the Stages of the Selection Process

To defend adverse impact, contractors may be asked by OFCCP to identify the various stages of their selection process and to track candidates through each stage. Setting up stages and assigning disposition codes to the candidate at each stage will allow you to conduct a step-analysis to determine each candidate’s outcome in the selection process. More specifically, how far they progressed, where they fell out and what was the reason for failing to progress.

For each stage in the selection process, which may also be referred to as the job seeker’s status, the candidate should be assigned a disposition. This will enable the contractor to determine if the candidate progressed through each stage in the selection process and/or identify the specific stage where their advancement ended. The following are sample stages which should be modified based on your own selection process. For instance, if the resume is initially reviewed and screened by a recruiter, then sent to the hiring manager for a second review, you would want to specify the various levels of review. The same may be the case for interviews that might be conducted by human resources personnel, the hiring manager, the executive team, etc.

Status Code	Stage or Status
Reviewed	Reviewed
Not Cons	Not considered – resume/profile not opened
PhScreen	Phone screen completed
Int-1st	1st interview completed
Int-2nd	2nd interview completed
Offer-Waiting	Position offered – waiting for response
Offer-Decl	Offer declined
Hired-Ext	Offer accepted / External hire
Hired-Int	Offer accepted / Internal placement
Not Filled	Position on hold / cancelled / not filled

Dispositions/Rejection Reasons

Dispositions identify two things:

1. The reason why the contractor decided not to move forward with the candidate, or
2. The reason why the candidate opted out of the process.

Most applicant tracking systems (ATS) track the job seeker’s movement through the recruiting process and allow for dispositioning at each stage. It is imperative that all candidates are assigned a disposition code when the position/job requisition is filled. If a candidate is not assigned a disposition, it will be impossible to determine if they met the four-steps of the internet applicant rule to be counted in the AAP data. This will lead to overcounting of these applicants who may not have met the basic job qualifications or self-withdrew.

Avoid the urge to take a short cut and mass assign the same disposition to candidates without ensuring that you can defend your selection. This may be the easiest way to go through the process but definitely not the safest. Keep in mind that there is the possibility that an OFCCP compliance officer (CO) may want to review the job posting or job description to compare the job requirements against the candidate’s skills, experience and education on the resume. The CO’s goal is to assess whether the candidate did or did not possess job related basic qualifications based on the preset criteria of the position. The internet applicant rule indicates that a third party, who may not have direct knowledge of your organization or the specific position, should be able to review the job description and determine if the job seeker possesses the basic qualifications necessary to perform the job.

Sample Scenario: Your offer has been accepted and you are about to close the requisition. You realize that you have not recorded a disposition at each stage or the final stage in which the candidate failed to advance. You may be inclined to take the quick route and identify the same disposition for all remaining candidates not hired. For this illustration, let’s say that you assign every candidate that is not selected the disposition of “more qualified candidate selected – experience.” If you don’t have an OFCCP audit within the next several years, you may have gotten lucky. However, if there is adverse impact in the job group, you may have to provide OFCCP with information to support your hiring decision. If this review does not confirm that the hire had more experience than all other applicants, the selection of this disposition code may come back to haunt you. You may be forced to go back and manually review each applicant’s resume to determine where and why they fell out in the process. Needless to say, this task will not be pleasant!

The following are sample dispositions which, as recommended above for stages, should be customized based on the selection process within your organization. For instance, if you do not require a written test, there is no need to include that disposition.

Disposition Code	Dispositions - Rejection Reason
Filled	Applied after position was filled
No Relo	Company not willing to pay for relocation
No BQ-cert	Does not meet basic qualifications – certifications/licenses
No BQ-educ	Does not meet basic qualifications – education
No BQ-exp	Does not meet basic qualifications – experience
No BQ-skills	Does not meet basic qualifications – skills
No BQ-clearance	Does not meet basic qualifications – security clearance
Failed-Bkgd Ck	Failed background check – post offer
Failed-Drug	Failed drug screen – post offer
Failed-Med Exam	Failed medical exam – post offer
Failed-test	Failed written test
Falsified Info	Falsified or misrepresented skills/experience/education
Prime Reject	Government or prime rejected
MQC-educ	More qualified candidate selected – education
MQC-exp	More qualified candidate selected – experience
MQC-skills	More qualified candidate selected – skills
No rehire	Not eligible for rehire – former employee
Not US Elig	Unable to work in the U.S.
W-NCNS	Withdrew – did not show for interview, test, work
W-No contact	Withdrew – did not return phone calls/could not contact
W-schedule	Withdrew – hours/schedule unacceptable
W-unknown	Withdrew – reason unknown
W-salary	Withdrew – salary unacceptable
W-travel	Withdrew – unwilling to travel
W-relo	Withdrew – unwilling to relocate
W-vol	Withdrew – voluntarily from consideration

Takeaway Tips

Here are a few tips to help you set-up and maintain a useful applicant tracking system.

• Always customize the stages/status and disposition codes instead of relying on the standard ones preset in your electronic ATS.
• Train all employees who are involved in the applicant tracking process and make sure that they understand their role, responsibility and risk involved in properly maintaining candidate data.
• Clearly articulate the basic qualifications for each position so that reviewers/screeners have preset criteria for consistently evaluating candidates.
• Accurately assign a disposition for all candidates reviewed at each stage and ensure that it can be supported by an assessment of qualifications against job criteria.
• Refrain from mass dispositioning candidates once the selection decision is made.

Summary

We all know what happens when OFCCP starts asking for support of hiring decisions that may have occurred over the past several years. Either hiring managers have left the organization or their memory has faded, particularly if your organization has a lot of job openings and subsequent large numbers of candidates.

Even though collecting and tracking disposition data on applicants is a challenge for many organizations, it is easier to do it correctly upfront than having to recreate the data months or years from the hiring decision. It is best to work with your compliance team to help select the right applicant tracking system for your organization and to properly set up the stages and disposition codes at the implementation stage. Educating staff and making the process as simplistic as possible should lead to accurate recordkeeping.

Disclaimer: The foregoing has been prepared for the general information of readers of The OFCCP Digest and is not being represented as being all-inclusive or complete. It is not meant to provide legal advice with respect to any specific matter and should not be acted upon without professional counsel.