OFCCP recently updated its Frequently Asked Questions (“FAQs”) on the implementation of the Vietnam Era Veterans’ Readjustment Assistance Act(“VEVRAA”) and Section 503 of the Rehabilitation Act final rules. The most recent VEVRAA FAQs address questions regarding data collection analysis and the term “jobs filled,” self-identification at the pre-offer and post-offer stages, and hiring benchmarks. The Section 503 FAQs address questions regarding whether a contractor must hire an individual with a disability who is not the best qualified candidate and whether a contractor fulfills its obligation to invite employees to self-identify when it does so via an internet portal.
Most of the new requirements of the Final Regulations went into effect on March 24, 2014. For a summary of the Final Regulations, please review our comprehensive client alert or our Webinar concerning the Final Regulations. Proskauer has developed a comprehensive set of compliance materials to help contractors implement the new compliance obligations imposed by the Final Regulations.