Attention Fed Contractors
and Subcontractors:

OFCCP Seeks new Guidelines for
Vets Affirmative Action

Earlier this month the Office of Federal Contract Compliance issued proposed regulations that would impose new requirements on government contractors and subcontractors. If you do business with federal money, you generally are required to adhere to some degree of affirmative action requirements as to veterans. Here are the highlights:

1. For the first time, required “annual data tracking analysis” as to priority and regular referrals of veterans, including calculation of ratio of priority referrals to all referrals; all applicants who self-identified as veterans; total job openings and jobs filled; total number of protected veterans hired and ratio of protected veterans hired to total individuals hired; and other data

2. Tracking of such data for the current plan year and previous two years

3. Setting (also for the first time) benchmarks for hiring veterans, similar to the goals for hiring women and minorities; the employer will be required to adopt benchmarks based on average percentages of veterans in the state where the employer is located, and other employment data collection sources

4. Pre-employment solicitation that applicants self-identify as “veterans,” including as disabled veterans (currently the requirement is that this occur post-offer)

5. New, required outreach efforts, e.g, linkage between the contractor and the Local Veterans’ Employment Representative, the Veterans’ Affairs Regional Office, veterans’ counselors on local college and university campuses, local veterans’ groups, and other specifically named sources.

Comments from the public in response to the proposal are due June 27, 2011. You may direct them in writing to the OFCC.