On March 24, Section 503 of the Office of Federal Contract Compliance Programs’ (OFCCP) Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRA) become effective. If you’re a contractor, subcontractor or federal depository of money with an affirmative action plan starting after that date, you will need to update your plans.
Attorneys at Williams Mullen advise that regardless of the dates of your plan, there are many non-plan requirements that will apply to all contractors from March 24 onwards. Here are a few of them:
- Incorporate new EEO language into all new contracts and any existing contracts that you’re renewing, modifying or extending.
- Incorporate the new EEO policy statement language into recruiting advertisements and internal job postings.
- Start using the new invitations to self-identify with all applicants for positions—and track this information.
- Survey all current employees about disability or protected veteran status and maintain records of the results. Schedule another survey for 2019.
- Schedule an interim reminder for 2016 to inform employees that they may voluntarily update their status.
- Keep a record of all accommodation requests and responses.
- Offer training to all those involved in hiring, promotions and terminations.
