OFCCP has just released three new FAQs regarding the partial year data and analysis required for the Section 503 and VEVRAA items in the revised scheduling letter. As presented in a previous blog, FAQs regarding how to submit compensation data under the new scheduling letter have also been posted.
First, OFCCP has clarified that contractors have two options for providing partial year data under items 9 and 13. These items require contractors to submit the 44(k) analytics under Section 503 and VEVRAA (data points are: job openings, jobs filled, total applicants and hires, total disabled/protected veteran applicants and hires). OFCCP states that contractors who are six or more months into their AAP when the scheduling letter is received must either (1) compute and submit the partial year data points or (2) provide the records showing the number of job openings, jobs filled, applicants and hires such that OFCCP can compute the totals for the contractor.
Second, OFCCP has clarified that contractors have two options for providing partial year data under item 10. This item requires contractors to perform and submit a partial year version of the disability utilization analysis required annually under Section 503. OFCCP states that contractors who are six or more months into their AAP when the scheduling letter is received must either (1) compute and submit the partial year utilization analysis or (2) provide OFCCP with the information necessary to perform the analysis for the contractor.
Third, OFCCP has clarified the partial year requirements under item 14. This item requires contractors to submit documentation of the hiring benchmark adopted and states that contractors who are six or more months into their plan year when the letter is received should submit “information that reflects current year results.” As we know, there is no “result” required in the regulation. The new OFCCP FAQ confirms this, stating that contractors who are six or more months into their plan year need only document the hiring benchmark adopted for the current AAP year.
By Kristen Pryor, M.S., Associate Consultant, DCI Consulting Group