You aren't alone if you are spending a lot of time reading the recent changes to the regulations that govern affirmative action plans for veterans and individuals with disabilities. While some of the changes are allowed to be phased in at the start of the next plan year, other changes took effect March 24, 2014, making now a great time to review your policies and procedures so that you can meet your training and recordkeeping obligations.
The requirement that "all personnel involved in the recruitment, screening, selection, promotion, disciplinary, and related processes" be trained to ensure the contractor's commitments in its AAP are implemented is not a new one, but it is a sure bet that the OFCCP will be looking at what contractors have done to satisfy that obligation given all of the new requirements. The OFCCP will also be looking at what records contractors have been keeping to verify their training activities. Here are some practical steps you can put in place now.
First, make sure you have appropriate training in place and that you have updated the content so that your training includes the recent changes. Important changes include increased data collection requirements, enhanced requirements to track and improve the external dissemination of the policy, and the contractor's outreach and positive recruitment efforts, and changes to the self-identification process. Additionally, the new 7% utilization goal for individuals with disabilities, as well as the new hiring benchmark for veterans should be included in the training and revised policies and procedures.
Second, make sure that anyone involved in the training efforts is carefully tracking the time and substance of these efforts, as the new regulations require contractors to keep these records for two years.
Third, be sure to incorporate the training efforts and changes you have made to comply with the new regulation directly into your affirmative action plan. This will demonstrate to the OFCCP that you are taking the appropriate steps to comply with the new rules, which may help should you become subject to an audit.