On September 30, 2014, the Office of Management and Budget approved the Office of Federal Contract Compliance Programs' (OFFCP) revised Scheduling Letter, Itemized Listing and Compliance Check Letter covering the Executive Order 11246 non-construction, supply and service aspects of the agency's program.
The revisions to these documents were made primarily to enable the OFCCP, as part of their compliance checks/evaluations, to determine contractor compliance with the requirements imposed by the revised Section 503 and VEVRAA regulations which took effect on March 24, 2014.
The revisions to these documents were made primarily to enable the OFCCP, as part of their compliance checks/evaluations, to determine contractor compliance with the requirements imposed by the revised Section 503 and VEVRAA regulations which took effect on March 24, 2014.
In particular, and with respect to Section 503 and VEVRAA, the Itemized Listing contains additional sections requesting documentation of: (1) the contractor's evaluation of the effectiveness of its outreach and recruitment efforts pertaining to individuals with disabilities and protected veterans; (2) all actions taken to comply with applicable audit and reporting requirements; and (3) computations or comparisons for the immediately preceding AAP year.
BACKGROUND
The OFCCP is part of the U.S. Department of Labor and is responsible for enforcing, "for the benefit of job seekers and wage earners, the contractual promise of affirmative action and equal employment opportunity required of those who do business with the Federal government.
Among the laws the OFCCP is charged with enforcing are Section 503 of the Rehabilitation Act of 1973, as amended (Section 503), which pertains to individuals with disabilities, and the Vietnam Era Veterans' Readjustment Act of 1974, as amended (VEVRAA), which pertains to protected veterans.
Section 503: The general requirements of Section 503 apply to government contracts and subcontracts in excess of $10,000. In addition, contractors with at 50 or more employees and a contract of $50,000 or more are subject to Section 503's affirmative action program requirements.
VEVRAA: The general requirements of VEVRAA apply to government contracts and subcontracts in excess of $100,000. In addition, contractors with 50 or more employees are subject to VEVRAA's affirmative action program requirements.
As mentioned earlier, in March of this year, the OFCCP's revised regulations with respect to Section 503 and VEVRAA took effect. The new rules impose significant new reporting, record-keeping, record management, administrative and affirmative action obligations on covered contractors. Although the new regulations contain a grace period with respect to the affirmative action program requirements, we recommend that all contractors subject to these requirements take steps to ensure they are in compliance or will be in compliance for their next plan year.
For more information on Affirmative Action Plans and compliance with OFCCP regulations, please contact us at 808.369.9710 or through our Contact Page.
The revised documents can be found here:
Scheduling Letter
Compliance Check Letter
Itemized Listing
BACKGROUND
The OFCCP is part of the U.S. Department of Labor and is responsible for enforcing, "for the benefit of job seekers and wage earners, the contractual promise of affirmative action and equal employment opportunity required of those who do business with the Federal government.
Among the laws the OFCCP is charged with enforcing are Section 503 of the Rehabilitation Act of 1973, as amended (Section 503), which pertains to individuals with disabilities, and the Vietnam Era Veterans' Readjustment Act of 1974, as amended (VEVRAA), which pertains to protected veterans.
Section 503: The general requirements of Section 503 apply to government contracts and subcontracts in excess of $10,000. In addition, contractors with at 50 or more employees and a contract of $50,000 or more are subject to Section 503's affirmative action program requirements.
VEVRAA: The general requirements of VEVRAA apply to government contracts and subcontracts in excess of $100,000. In addition, contractors with 50 or more employees are subject to VEVRAA's affirmative action program requirements.
As mentioned earlier, in March of this year, the OFCCP's revised regulations with respect to Section 503 and VEVRAA took effect. The new rules impose significant new reporting, record-keeping, record management, administrative and affirmative action obligations on covered contractors. Although the new regulations contain a grace period with respect to the affirmative action program requirements, we recommend that all contractors subject to these requirements take steps to ensure they are in compliance or will be in compliance for their next plan year.
For more information on Affirmative Action Plans and compliance with OFCCP regulations, please contact us at 808.369.9710 or through our Contact Page.
The revised documents can be found here:
Scheduling Letter
Compliance Check Letter
Itemized Listing
