A Contractor’s Expert Guide to the Section 503 Focused Review
In 2019, the labor force participation rate for all individuals aged 16 and older was 68.7%. In contrast, the rate for individuals with disabilities was just 20.8%.
Recognizing this disparity, the federal government aims to reduce barriers to equal employment for disabled workers. The Section 503 focused audit is a new but important component of these efforts.
So what are Section 503 focused reviews? Who is subject to them? What happens during these reviews?
Find answers to these questions and more in this helpful guide.
What Is a Section 503 Focused Review?
Section 503 reviews are new and targeted audits. The Office of Federal Contract Compliance (OFCCP) implemented them in August 2018.
Section 503 focused reviews target employment practices related specifically to disabled workers.
Section 503 of the Rehabilitation Act of 1973 governs federal contractors. It prohibits them from discriminating against individuals with disabilities. It requires them to take affirmative action to recruit and hire disabled workers. Finally, it demands affirmative action to promote and retain disabled employees.
Section 503 focused audits assess contractors’ compliance with these requirements.
Who Is Subject to Section 503 Focused Reviews?
Contractors and subcontractors providing more than $15,000 of goods or services to the federal government must follow Section 503 requirements.
Other requirements, including a written Affirmative Action Plan (AAP), apply to contractors with more than 50 employees and contracts of $50,000 or more.
The federal contractor scheduling system randomly selects these larger contractors for Section 503 focused reviews. The initial round of a Section 503 investigation focuses on the contractor’s headquarters. However, the OFCCP reserves the right to schedule future reviews at other establishments.
What Happens During a Section 503 Focused Review?
Contractors selected for a Section 503 review will receive a scheduling letter. This letter will list the documents and data the contractor is required to submit.
Required submissions include the contractor’s E.O. 11246 and Section 503 AAPs. They also include documentation showing the contractor’s efforts to comply with other OFCCP policies. Finally, they include data from the contractor’s internal assessments of its employment practices.
Contractors must submit the required documents within 30 days of receiving the letter. Electronic submissions are preferred.
Besides reviewing submitted documents, OFCCP will conduct an on-site investigation. During this investigation, OFCCP compliance officers will interview managers, especially those responsible for Section 503 compliance. Compliance officers will also interview employees affected by Section 503 policies.
During Section 503 reviews, contractors are exempt from scheduling other compliance evaluations.
The OFCCP also assures contractors that Section 503 reviews will remain focused. It will not look for discrimination based on other criteria, like race or sex.
Still, if it receives a discrimination complaint during the review, the OFCCP will investigate.
What Steps Can Contractors Take to Ensure Successful Completion of the Review Process?
Completing the Section 503 focused review process requires being knowledgeable about the process. The OFCCP website provides resources to help contractors navigate these reviews.
Yet even these educational resources can be overwhelming. Fortunately, consulting services, like Career Resources, Inc., can help.
The professionals at CRI are experts in employment law. Moreover, their expertise includes the most recent updates to OFCCP regulations. They are also experts in developing employment policies, including AAPs, that meet these regulations.
Contractors that work with CRI are ready to respond to scheduling letters—for a Section 503 review or a broader OFCCP audit—before they arrive. They’re also well-positioned not only to follow but to exceed requirements.
During the review process, the OFCCP looks for such innovative and inclusive employers. Its Contractor Recognition Program highlights diverse workplaces and provides other incentives.
Navigate the Section 503 Focused Review Process with CRI
Section 503 focused reviews are important to ensure diversity in the workplace. Still, the complexity of federal law can make these reviews intimidating for contractors.
Learning more about the process makes these reviews easier to navigate. Doing so with a CRI consultant is even better.
Contact CRI to talk to one of our experts today.