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The Office of Federal Contract Compliance Programs (OFCCP) recently posted sample affirmative action plans (AAPs) for individuals with disabilities and veterans to its website, available here.
The forms should be helpful guidance for companies who are federal contractors and subcontractors who are looking to comply with new regulations that took effect on March 24,…
The Office of Federal Contacts Compliance Programs (OFCCP) has been very busy changing the rules for federal contractors and subcontractors. There are 8 new developments from the second half of 2014 that all covered contractors should be aware of:
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Those of you who watched President Obama’s State of the Union Address know he announced that he will establish by Executive Order a minimum wage of $10.10 for all federal contractors and subcontractors. A proposal backed by the White House is currently pending in Congress to raise the federal minimum wage for all employers from $7.25 to $10.10. There is strong opposition to the proposed law. The President’s anticipated Executive Order does not need Congressional approval because it will not impact all employers, just those who have federal contracts or subcontracts. …
Continue Reading Updates for Federal Contractors: New Minimum Wage Coming Soon; New Required Form for Self-Identification of Disability Published by OFCCP.
Companies covered by federal affirmative action obligations have some major changes for which to prepare. The Office of Federal Contract Compliance Programs (OFCCP) has issued two new rules which take effect March 24, 2014. The new rules expand the affirmative action requirements for covered veterans and disabled persons.
For over 30 years, regulations under the Vietnam Era Veterans Readjustment Assistance Act of 1974 (VEVRAA) and under Section 503 of the Rehabilitation Act of 1973 have required covered employers to engage in good faith efforts to recruit and employ covered veterans and disabled persons. The requirements include the obligation to invite applicants and employees to “self-identify” as a veteran or disabled person and to take additional affirmative action measures. Contractors with over 50 employees and covered contracts which exceeded certain trigger limits also must prepare annual written affirmative action plans (AAPs) for veterans and disabled persons. However, until now, there was no obligation for employers to develop and retain hiring and other employment data or to set numeric goals for employment of veterans or disabled persons, as is required in the affirmative action rules for minorities and females.
The new rules require employers to gather and retain data showing the results of their recruiting and hiring efforts and to set numeric targets for hiring veterans and disabled persons. The new rules also include significant additional obligations for reviewing, analyzing, and documenting good faith efforts and results.
Continue Reading Major Changes to Affirmative Action Requirements Effective March 24, 2014
The Office of Federal Contract Compliance Programs (OFCCP) recently released a notice that the 2006-2010 census data must be used for all affirmative action plans for plan years beginning on January 1, 2014, and OFCCP will begin using 2006-2010 census data to evaluate affirmative action plans and efforts as of that same date. Keep in…
The Office of Contract Compliance (OFCCP), which enforces federal contractors’ and subcontractors’ affirmative action obligations, recently rescinded its 2003 ACM directive. The 2003 ACM or "Active Case Management" directive allowed for abbreviated desk audits where only the affirmative action plan and personnel data were reviewed. If no evidence of systemic discrimination was revealed (defined as discrimination affecting…
As previously reported, many federal contractors will be required to file their first annual VETS-100A report by September 30, 2009 based on a final rule issued earlier this year. In order to complete the new report, federal contractors covered by the new rule must start collecting the required data no later than August 31, 2008.
The VETS-100A, like the VETS-100, requires a federal contractor to have 12-months of data collected. The 12-month period must end on a date between July 1 and August 31, 2009. Likewise, this means that the contractor must begin collecting the data between July 1 and August 31, 2008. If you are a federal contractor, and if you will be required to fill out the new VETS-100A form, you should either already be collecting data or must start collecting it before August 31. Continue Reading Federal Contractors May Need To Be Collecting Data for New Vets-100A Form
Employers with federal contracts worth $100,000 or more entered into on or after December 1, 2003 will now be required to file a new form, VETS-100A, with the Veterans’ Employment and Training Service (VETS). Covered federal contractors must begin collecting the new information this summer and file their first annual reports on the VETS-100A form by September 30, 2009.
Employers working on federal contracts of $25,000 or more that predate December 1, 2003 must continue to file the VETS-100 form. Some employers with contracts falling into both categories will be required to file both forms, although VETS predicts that most contractors will file either the VETS-100 form or the VETS-100A form but not both. Modifications of pre-December 2003 federal contracts made on or after December 1, 2003 create new contracts. Contractors subject to such modified contracts need only track and report under the new VETS-100A form for the modified contract – and only if the contract meets the $100,000 threshold.Continue Reading VETS Issues Final Rule for Filing VETS-100A Form
