As previously featured on this blog, the Department of Labor’s OFCCP published the revised Section 503 and VEVRAA regulations on September 24, 2013. The effective date for all contractors to comply with subparts A, B, D, and E is 180 days from the date they were published, which will be March 24, 2014. Contractors may have additional time for Subpart C. OFCCP has also addressed the phased in compliance in their FAQS (Section 503 and VEVRAA).
As March 24th is quickly approaching, contractors should make sure they have the following changes in place by this effective date:
- Change “other protected veteran” to “active duty wartime or campaign badge veteran.”
- Provide new required information to each employment service delivery system (ESDS) with next job listing.
- Verify job openings are being submitted to each ESDS in a manner “permitted” by that ESDS.
- Ensure the “EEO is the Law” poster is provided in format “accessible and understandable” to individuals with disabilities and protected veterans.
- Ensure remote employees can access the poster, and that there is a conspicuous link to the poster in online application systems.
- Update contract and purchase order templates to include new required bold language citations.
- Notify labor unions of affirmative action and non-discrimination obligations and request cooperation.
- Update EEO tagline to include reference to protected veteran and individuals with disabilities.
- Continue to provide reasonable accommodations to ensure individuals with disabilities have equal access to personnel processes.
- Update recordkeeping guidelines to 3 years for documentation of outreach and recruitment evaluation, data collection analysis, and VEVRAA hiring benchmark.
by Kristen Pryor, M.S., HR Analyst and Amanda Shapiro, M.S., Consultant, DCI Consulting Group