Tag Archives: Section 503

Director Leen Shares OFCCP Update

OFCCP Director Craig Leen thinks the Agency has made good progress on implementing “the four pillars” but there is still work to be done. Speaking this week in Florida, Director Leen shared accomplishments, and things to come, for each of the four tenants.  However, he noted he was not allowed to comment on the pending … Continue Reading

OFCCP Proposes Construction Compliance Check Letters

In furtherance of its work as an enforcement agency and its commitment to conduct reviews of more contractors, OFCCP posted in the Federal Register on Monday, April 8, 2019 its proposal for a series of compliance check audit letters for construction contractors. The agency is request feedback on two proposed construction compliance check letters  – federally assisted versus a direct federal … Continue Reading

OFCCP – Here to Stay or Not? Signs Indicate OFCCP Will Survive

With the transition to a new presidential administration well under way, everyone is looking for signs to help predict the future.  Given President Trump’s sweeping executive action, including entering an Executive Order requiring the identification of two regulations to be eliminated for every new regulation proposed, the question of whether the make-up of the federal agencies as we … Continue Reading

Will OFCCP bring back Courtesy Scheduling Announcement Letters in 2017?

Happy New Year! As we ring in 2017 and prepare for affirmative action and OFCCP compliance in a Trump administration, many contractors are wondering whether 2017 will bring an OFCCP audit their way. Some may remember in years past around this time OFCCP would send out Courtesy Scheduling Announcement Letters (CSALs) providing advance notification to contractors of … Continue Reading

OFCCP Releases Disability Self-Id Public Service Video

As part of its ongoing effort to provide employers with tools to educate and inform employees and non-employees about affirmative action obligations, OFCCP has released a new disability self-identification public service-like video entitled Disability Inclusion Starts With You.  Coinciding with its recognition of National Disability Employment Awareness Month, the Agency invites employers and community organizations to download … Continue Reading

OFCCP Releases Informational Section 503 Compliance Checklist

As a continuation of its recent education and outreach efforts, OFCCP released a Checklist for Compliance with Section 503 of the Rehabilitation Act of 1973.   The checklist was developed by the U.S Department of Labor’s Office of Disability Employment Policy (ODEP) and covers obligations under Subpart C of the revised Section 503 regulations. The checklist is … Continue Reading

It’s Been Six Months Since OFCCP Issued its Revised Scheduling Letter – What Have We Learned?

Since introducing its new scheduling letter in late 2014, OFCCP has made many important changes to enforcement in audits.  From ramped up enforcement of the Agency’s VEVRAA and Section 503 regulations to new and very different ways to investigate pay systems for discrimination, the Agency has fundamentally changed how it conducts compliance reviews.  And it’s … Continue Reading

VEVRAA and Section 503 Six Month Update Obligations Under the New Scheduling Letter

In FAQs released yesterday, OFCCP addressed requirements under the new Scheduling Letter for contractors to provide updated data collected pursuant to the revised Veterans and Individuals with Disability regulations if the contractor is more than six months into its current AAP plan year upon receipt of a Scheduling Letter. OFCCP has previously indicated a contractor’s compliance with … Continue Reading

OFCCP Releases Additional FAQs for Compliance with Veterans and Disability Regulations Under the New Scheduling Letter

Adding to the FAQs previously released, OFCCP has released additional guidance addressing audit submission requirements under the new Scheduling Letter for contractors more than six months into their plan year when the Scheduling Letter is received. Items 9 and 13 of the Scheduling Letter require contractors to provide documentation of the computation or comparisons called … Continue Reading

OFCCP Posts New Section 503 and VEVRAA Guidance

As it has done periodically since the release of the new regulations, OFCCP has posted six new “frequently-asked questions” (FAQ) regarding the revised VEVRAA and Section 503 Regulations.  Each is highlighted with a “new” tag.  The FAQs are responsive to questions we’ve been hearing – and some asked during the SWARM conference during the Q&A session … Continue Reading

Dissemination of Your EEO Policy: Are You Requesting “Cooperation” and “Appropriate Action” from Your Unions and Vendors?

With March 24th come and gone many employers are still working on implementing the required elements of OFCCP’s new veteran and disability regulations and making preparations for rolling-out Subpart C compliance measures. As of March 24th, contractors who are party to a collective bargaining agreement (CBA)  “shall notify union officials and/or employee representatives to inform them of … Continue Reading

OFCCP Launches A New Outreach and Recruitment Database for Contractors

In addition to releasing the veteran benchmark database, OFCCP has also launched a new outreach and recruitment database for use by contractors in connection with implementation of the new veteran and disability regulations. The OFCCP’s Disability and Veterans Community Resources Directory can be found on the OFCCP Web site athttp://www.dol-esa.gov/errd/index.html.  This new resource supplements the agency’s … Continue Reading

Which is Which: Getting All the Required EEO Notices in Place in Time for March 24th

As the last few days before the new veteran and disability regulations go into effect, we wanted to take moment in our  Countdown to March 24th Effective Date: Are you Ready to Flip the Switch series to help you clarify (and check-off) the obligations with respect to the various EEO notices, policy and posting requirements under the … Continue Reading

Assessing the Effectiveness of Your Outreach Efforts after March 24th

In today’s post as part of our “Countdown to March 24th Effective Date: Are you Ready to Flip the Switch?” series, we’ll be discussing the new obligation under the veterans and disability regulations that employers must now “assess the effectiveness” of their good faith outreach programs. Back in 2011 when OFCCP first released the proposed … Continue Reading

State Listing Requirements: What Should You and Your Vendor Be Doing After March 24th?

Today’s installment of our “Countdown to March 24th Effective Date: Are you Ready to Flip the Switch?” series focuses on the enhanced obligations involving posting positions with state employment services. Under the current VEVRAA regulations employers are required to list appropriate job openings with the state Employment Service Delivery System (ESDS) in the state where … Continue Reading

Notifying Applicants of EEO Rights…after Monday March 24, 2014

As the next installment of our “Countdown to March 24th Effective Date: Are you Ready to Flip the Switch?” let’s take a look at what employers need to be telling Job Seekers after March 24th . . . A number of the new veteran and disability obligations effective March 24, 2014 involve notifying job seekers that your … Continue Reading

Countdown to March 24th Effective Date: Are you Ready to “Flip the Switch?”

Today will mark the first in a series of posts over the next week counting down to the March 24th effective date for OFCCP’s new Veteran and Disability regulations. During the next week we will seek to provide you with practical pointers and tips as you work through your checklists and prepare to “flip the … Continue Reading

OFCCP Provides Additional Guidance on Purchase Order Language and Other Requirements of the New Veterans and Disability Regulations

In an effort to provide continuing guidance to the contratcor community as the effective date for the revised VEVRAA and Section 503 regulations quickly approaches,OFCCP has released additional FAQs addressing questions about required Purchase Order Language as well as the obligaiton to “conspiculously store” the notice of applicant and employee rights with an electronic application. … Continue Reading

The OFCCP Institute to Provide the Latest Information on Implementation of Veterans and Disability Regulations

As the effective date for OFCCP’s new veterans and disability regulations nears, the Agency continues to present webinars, publish FAQs and provide other guidance in the hopes of clarifying what remains a less than a clear picture of these new obligations.  Despite the OFCCP’s laudable attempts, employers are still searching for answers as March 24th rapidly … Continue Reading

OMB Approves OFCCP’s Revised Self-Identification of Disability Form

Under OFCCP’s new 503 regulations covering individuals with disabilities, employers are required to use a form prescribed by OFCCP to solicit disability status of applicants and employees.  After receiving questions and input from contractors on an initial draft form, OFCCP has modified, and received approval of a final version of the form. In response to … Continue Reading

The OFCCP Institute Offers Practical Tips in Preparation for the New Vets and Disability Regulations

March 24, 2014 – the effective date for OFCCP’s new veterans and disability regulations – is fast approaching.   The Agency continues to present webinars, publish FAQs and provide other guidance in the hopes of clarifying what remains a less than a clear picture of these new obligations.  Despite the OFCCP’s laudable attempts, employers are still … Continue Reading

Upcoming OFCCP Webinars on New Vets and Disability Regulations

On December 17, OFCCP held the first of what will be several public webinars in an effort to provide assistance to the contractor community with implementation of the new Veterans and Section 503 regulations.  The series of trainings, entitled “Moving Toward Compliance: Training Webinars on SEction 503 and VEVRAA” will cover topics such as developing AAPs (Jan. … Continue Reading

OFCCP Answers Questions Surrounding Compliance with “Subpart C” of the new Veterans and Disability Regulations

In a public webinar and new FAQs released today, OFCCP answered questions around timing of compliance with obligations set forth in Subpart C of the Agency’s new Veterans and Disability regulations.  OFCCP sought to clarify and clear up what has been widespread confusion about the timing of required compliance with the data collection aspects of … Continue Reading
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