In August 2018, OFCCP released Directive 2018-04 announcing the Agency’s implementation of Section 503 Focused Reviews. Long a priority Director Craig Leen, the Agency is hopeful the reviews will improve compliance with the regulations and promulgate EEO for Individuals with Disabilities. OFCCP has indicated it will start scheduling the Section 503 Focused Reviews with the Agency’s upcoming round of CSALs.

When first announced, there were many questions surrounding what information OFCCP would request while conducting a Focused Review. Late in 2018, OFCCP obtained approval for an abbreviated Section 503 Scheduling Letter, confirming the Agency would be requesting a subset of data provided in a traditional review during the focused reviews.

On Friday, OFCCP provided additional insight and guidance with the launch of a new Section 503 Focused Review landing page. In addition to providing a sample of the Focused Review Scheduling Letter, the website also includes a list of employer best practices and resources as well as a set of FAQs.

Here are some of the highlights of the FAQs:

  • At least initially, OFCCP will conduct Section 503 Reviews at a contractor’s corporate headquarters. 
  • OFCCP will not review the contractors Executive Order 11246 AAP during a Section 503 Review; however, submission of the EO 11246 AAP (not including supporting data e.g. Items 18 and 19 of the EO Scheduling letter) is required as part of the initial submission.
  • OFCCP will not schedule contractors for other compliance reviews while undergoing a Section 503 Review.
  • OFCCP will not require submission of personnel data for a Focused Review other than data required by 41 CFR §60 741.44(k). After reviewing data, OFCCP may request applicant flow data for job groups containing applicants with disabilities.
  • Compliance officers may request compensation and promotion data for individuals who identified as having a disability, are known to have a disability, or have requested a reasonable accommodation.

OFCCP has announced that it would release the next round of CSALs in the second half of March. OFCCP will publicly release these CSALs on its website with actual scheduling letters to follow by mail beginning 15 days later.

We’ll continue to monitor and report on the latest developments in the coming weeks so stay tuned.

Tags: CSAL, CSALs, Focused Reviews, OFCCP, Office of Federal Contract Compliance Programs, Scheduling Letter, Section 503 FAQs, Section 503 Focused Reviews, Section 503 of the Rehabilitation Act of 1973
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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.

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