As previously discussed in this blog post, the revised VEVRAA regulations became effective for Federal contractors on March 24, 2014. Although some contractors may have additional time for Subpart C, the rest of the requirements went live on the effective date, including the notification that must be provided to each employment service delivery system (ESDS) with whom the contractor lists jobs. The timing of this communication is important – the regulations state that this communication “shall be made simultaneously with the contractor's first job listing at each employment service delivery system location after the effective date of this final rule.”
It is important that the ESDS notifications are (a) sent at the same time as a job listing with that state office and (b) sent with the job listing (e.g., not a separate, blanket email/letter). Although it may seem strategic to send in your information “early” to the ESDS, they may not accept it because it was not sent per the regulatory requirement (e.g., simultaneous with the first job listing after March 24, 2014). If the notifications have already been sent to the state office(s) without a posting) you may want to follow-up with the state or resend the communication with the first job listing to that ESDS. According to the National Association of State Workforce Agencies (NASWA), states are currently in the process of developing policies and procedures around the additional requirements found in the VEVRAA job-listing provisions, including a central point of contact for OFCCP questions. Stay tuned for more information.
As a reminder, the information you’re required to include in the notification to the state is:
- Status as a federal contractor (e.g., noting “VEVRAA Federal Contractor” on the listing)
- Desire for priority referrals of protected veterans for openings
- Contact information for the contractor official responsible for hiring at each hiring location who can verify the information in the job listing
- If the information in the notification changes after it was reported to the ESDS, the regulations require that the updated information is sent simultaneously with its next job listing.
By Amanda Shapiro, M.S., Consultant and Yesenia Avila, M.P.S., HR Analyst, DCI Consulting Group