Are You Ready For Next Week's New Affirmative Action Requirements?

Across the country, federal government contractors are preparing to meet next week’s deadline for starting to comply with new affirmative action rules.  Last fall, the Office of Federal Contract Compliance Programs (OFCCP) announced new affirmative action rules related to individuals with disabilities and protected veterans.  Those new rules become effective next week on Monday, March 24, 2014.  Some of the new requirements imposed by the rules have a March 24th compliance deadline.  Others can wait until a contractor currently in the middle of its affirmative action plan implements the following year’s plan.

The new federal affirmative action rules related to protected veterans apply to most federal contractors and covered subcontractors with a contract of at least $100,000 in value, with additional requirements for contractors with 50 or more employees.  In turn, the new rules related to individuals with disabilities apply to federal contractors and covered subcontractors with a contract of at least $10,000 in value, with additional requirements for contractors with 50 or more employees and a contract of at least $50,000 in value.

The new rules impose a number of changes related to affirmative action plans for individuals with disabilities protected by Section 503 of the Rehabilitation Act of 1973 and veterans protected by the Vietnam Era Veterans’ Readjustment Act of 1974 (“VEVRAA”).  Some of the more significant changes include:

• Updating affirmative action plan language, plan notices, subcontract language, job advertisements, and employment policies to comply with the new rules.
• Establishing a process for applicants to self-identify as a protected veteran or individual with a disability at various stages of the hiring process.
• Incorporating hiring and employment goals for protected veterans and  individuals with disabilities into affirmative action plans.
• Detailed recordkeeping requirements related to the recruitment and hiring of protected veterans and individuals with disabilities.
• A disability accommodation process that differs from obligations imposed by the federal Americans with Disabilities Act.

Whether or not you are required to comply with the new rules can be confusing. In addition, meeting the new requirements can be daunting and time consuming.  Feel free to contact us if you have questions or need compliance help.  We have developed a customizable compliance plan to help bring contractors into compliance with the new requirements.