2018 was a very busy year for federal contractors. Before we get too deep into 2019, let’s take a stroll through some of the highlights and what can be done to prepare for another busy year.
Corporate Scheduling Announcement Letters (CSAL) were sent to contractors twice in 2018. OFCCP has been busy scheduling compliance reviews from both lists. To find out if your organization is on either list, visit the OFCCP website to the Freedom of Information Act (FOIA) Library.
Last January we provided advice about preparing your data for Annual AAPs. This advice is still great for 2019 preparation, and below are some highlights.
Prepare to survey your current workforce for disability status! It has been almost five years since the regulations for Section 503 were revised. One of the new requirements is a survey of current employees to invite self-identification of disability status every five years. There is also a requirement to remind the active workforce in between surveys completed every five years, that disability status may be updated at any time. Some clients have moved to a four-year survey cycle to address both requirements.
Director Craig Leen has been busy since stepping into the lead role at OFCCP. He has issued directives promising transparency, creating an Ombud Service in the national office, outlining Early Resolution Procedures (ERP), providing information about Opinion Letters and a Help Desk feature, and rescinding Active Case Enforcement (ACE) Procedures. OFCCP also received approval for a revision to the Scheduling Letter to allow for focused reviews for AAPs for individuals with disabilities. Read more on each of these on our site.
We look forward to giving you more updates as 2019 gets into full swing.