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Contract Compliance 


Good Faith Efforts


Contractors and subcontractors must use good faith efforts (GFE)  to meet specific affirmative action goals. Under Executive Order 11246, workhour goals for women & minority utilization in each construction craft is 6.9%.

The workforce utilization goal for women and minorities throughout Pennsylvania is determined by geographic regions and is published in the Federal Register by the Office of Federal Contract Compliance (OFCCP). Although these goals are not treated as quotas, PennDOT uses them as targets for their recruitment and outreach efforts.

Executive Order 11246 applies to all federal contracts over $10,000. Due to this, the Office of Federal Contract Compliance has programs to enforce contractor compliance as it pertains to Title 41 Code of Federal Regulations Chapter 60; Executive Order 11246, as amended; Section 503 of the Rehabilitation Act of 1973, as amended; and the Vietnam Era Veterans Readjustment Assistance Act of 1974 (VEVRAA), as amended.

OFCCP has sixteen 16 affirmative action steps that contractors and subcontractors must follow to demonstrate GFE in the work place. If a contractor is audited by PennDOT's Contract Compliance Division, or OFCCP, both agencies will look for evidence that demonstrates each of these 16 affirmative action steps were followed. The 16 Steps are available in the Resources section. This information is essential for contractors to know and understand to ensure equal employment opportunity on the work site.

When a contractor cannot achieve its annual goals through the hiring of women and minorities, it must produce adequate documentation to prove its GFEs. GFEs are designed to support consistency in equal opportunity laws, through positive working experiences, aggressive recruitment efforts, and continuous result oriented measures.

PennDOT will consider all contractors' documentation of GFEs on a case-by-case basis, taking in to account the following:

  • Availability of disadvantaged business
  • Duration of the contract
  • Dollar value of the contract
  • Total normal work force contractor/subcontractor would be expected to use
  • Geographic location
  • Type of work