503 and VEVRAA Audit Activity: New Regulations Overshadowing Current Regulations?

 With the new 503 and VEVRAA regulations looming around the corner, we have recently experienced audits with an increased interest in the ‘raw’ data behind federal contractor’s outreach efforts. In fact, data requests are going beyond the narrative explanations and seem to more closely align with questions that may arise after the March 24, 2014 effective date.

Below is a sample of recent data requests that DCI has been privy to:

  • The number of applicants that self-identified as a veteran or person with a disability
  • A list of applicants referred, during the review period, who were identified as a qualified veteran, and/or individual with disabilities
  • Documentation of formal briefing sessions, preferably on company premises, with representatives from recruiting sources including,
    • Formal arrangements for referral of applicants;
    • Follow up with recruitment sources; and
    • Feedback on disposition of applications.
  • The number of individuals with disabilities hired
  • The number of veterans hired
  • A list of employees who have self-identified as individuals with disabilities

If presented with one of the above requests in a compliance review, how should you respond to the compliance officer? We suggest not denying access to information your organization has collected based on the current regulations (e.g., number of individuals with disabilities hired - - - obtained via voluntary self-identification post offer). However, if there are requests that go beyond what is required by the current regulations (e.g., list of applicants that self-identified as individuals with disabilities), we recommend addressing any concerns directly with the assigned compliance officer. If not resolved by the compliance officer, then it is appropriate to escalate up the chain of command to their superior, and ultimately the National office if it cannot be resolved locally.

by Yevonessa Hall, M.P.S, Associate Consultant and Keli Wilson, M.A., Senior Consultant, DCI Consulting Group

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