Revised VEVRAA and Section 503 regulations – have you implemented the changes?

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The new regulations for Protected Veterans and Individuals with Disabilities went into effect on March 24th. Now that we are four months into the new rules, you should be well into the stages of implementing the regulations.  According to the regulations, the changes are not required until the beginning of the next AAP cycle after March 24th; the OFCCP recommends that contractors comply as soon as possible. Below is a recap of the changes you should have already begun implementing:

  • Have you incorporated the new mandated OMB self- identification form for individuals with disabilities at the pre-offer and post-offer phase of the application process?
  • Are you inviting applicants the ability to self-identify as having a “protected veteran” status during the pre-offer and post-offer phase of the application process?
  • Do you have a process for ensuring that the protected veterans and individuals with disabilities status are captured in your system when individuals are hired?
  • Have you revised your post-offer self-identification form to include the new veterans’ categories?
  • Have you invited your present employees to self-identify as a disabled individual utilizing the mandated OMB self-identification form? You are required to ask your employees to self-identify within the first year after the regulations take place (3/24/14) and then again every five years after that.  You must also notify employees they can modify their disability status at any time at least once between the five years. Ensure you have a plan in place to gather this information.
  • Have you changed the tagline on your job postings to reflect the revised regulations incorporating references to protected veterans and individuals with disabilities? You may no longer use abbreviations such as M/F/D/V.
  • Have you modified your current EO clause in subcontracts to reflect the revised regulations?
  • Have you evaluated the overall impact of your outreach and recruitment for protected veterans and individuals with disabilities and documented this evaluation?
  • Have you provided alternative application methods for any applicants who are unable to use your online applicant system?
  • Does your company have a process for requests for reasonable accommodations in the employment process?

If you have not begun implementing the new regulations, you will want to start the process now. For a list of frequently asked questions regarding the new regulations regarding protected veterans, visit the OFCCP’s website http://www.dol.gov/ofccp/regs/compliance/faqs/VEVRAA_faq.htm.For a list of frequently asked questions regarding the new regulations for individuals with disabilities, visit the OFCCP’s website at http://www.dol.gov/ofccp/regs/compliance/faqs/503_faq.htm#Q44.

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