As the country honors all of the men and women who have sacrificed to serve our country, it is a good time to assess compliance with veteran focused OFCCP obligations.  

 Not missing a chance to focus on employing veterans, Department of Labor Secretary Hilda Solis issued a statement urging employers to commemorate the Veterans Day holiday by hiring veterans saying

 “the best way we can honor our veterans is to employ them.” 

She went on to further underscore the assistance veterans need in gaining employment by citing the dropping unemployment rate for Iraq and Afghanistan veterans.

Despite the fact OFCCP has been unable to finalize its proposed veterans’ regulations, the Agency is readily issuing violations to employers in connection with veterans obligations. 

Specifically, OFCCP is expecting employers to:

  •      Be able to demonstrate a commitment to outreach and not appear as having just gone through the motions.
  •      Monitor the number and quality of applicants referred by these sources and, as appropriate, change these sources.
  •      List all appropriate jobs with state employment services

It’s too late to start thinking about good faith recruitment efforts and posting with the state once you receive an OFCCP scheduling letter.  You need to think about getting into compliance now because OFCCP will expect to see 12 months worth of documentation in an audit. 

If recent OFCCP enforcement trends aren’t motivation enough to get into compliance, the fact that we can only expect to see continued enhanced enforcement for veterans and individuals with disabilities in a second Obama Administration should be.