As of March 24th, 2014 ALL Federal Contractors are now REQUIRED to make seven changes to comply with sub parts A,B,D and E of the regulations:
- In policy references, refer to “protected veterans,” instead of the old veteran categories.
- Change the EEO tag line in job listings from EOE AA M/F/D/V to EOE AA M/F/Vet/Disability.
- Include new required contract language in boldface.
- Tell the state employment service delivery system that the business is a federal contractor and wants priority referrals of protected veterans for job openings. Provide the contact information for the contractor official responsible for hiring at each site.
- Link to the Office of Federal Contract Compliance Program’s (OFCCP)EEO is the Law poster when using an electronic applicant tracking system.
- Provide this link on the intranet for employees who telecommute.
- Hold records for four years—one more than the three years required, up from two—to be on the safe side.
Part C of the disabilities and veterans rules will take effect at the start of federal contractors’ affirmative action year, according to Eric Felsberg, an attorney in Jackson Lewis’ Melville, N.Y., office. So if that coincides with the start of the calendar year, contractors have time to gear up for Part C’s 7 percent utilization goal for people with disabilities and 8 percent goal for veterans, he said.
But if the plan year starts much earlier, say April 1, the time to comply with the new rule across the board is near.
Contractors have always been responsible for providing affirmative action for people with disabilities and veterans, Felsberg noted. But under the new requirements they must comply in more specific ways.
Some believe they now must hire a certain percentage of people with disabilities or veterans, but that’s not true, Felsberg said. The goals are aspirational targets that the federal government would like businesses to hit. If not, the government will scrutinize the efforts that were made, so contractors should expect that to be where “the scrutiny is going to be.”
Allen Smith, J.D.