By Anthony J. Marchese
In September, I attended, on behalf of the Firm, a webinar given by attorneys from Miles & Stockbridge entitled Hiring and Employing Veterans and Individuals with Disabilities – How Federal Contractors Can Prepare to Meet New OFCCP Regulations. The presentation focused on the new requirements, which will become effective March 24, 2014, for federal contractors to take affirmative action to employ more veterans and persons with disabilities.
The presentation covered the substance of the changes to the Vietnam Era Veteran’s Readjustment Assistance Act (VEVRAA) and Rehabilitation Act (a number of which we’ve recently discussed on this blog), as well as providing insights on the steps that contractors can take in the short term to comply with the new rules.
Among other things, the new regulations require yearly documentation of contractors’ efforts to recruit and hire protected veterans. A contractor is required to complete quantitative comparisons of the number of protected veterans who apply for jobs and the number actually hired. The data must be maintained for three years.
The recent webinar also dealt with the need to prepare revised Affirmative Action Plans (AAPs).
The Affirmative Action Plan requirement may be new for your company, or you may have had one in place for years in order to comply with rules related to the hiring of women and minorities. In either event, your AAP will need to be updated. The question is whether you want to do so sooner or later.
When the new regulations become effective, you will not have to draft and implement a new AAP until the first rollover of your AAP plan year following that date. For example, if a company had a written affirmative action plan in place for a year starting on March 1, updating the AAP to meet the new VEVRAA and Rehabilitation Act requirements would not be required under the rules until March 1, 2015.
With proper planning in the months to come, you can give your company ample time to draft and prepare to implement a robust AAP for the future.