OFCCP released its directive (2018-04) to conduct compliance evaluations focused on the laws and regulations relating to individuals with disabilities on August 10, 2018. As federal contractors are aware, the OFCCP enforces three laws, Executive Order 11246, as amended, Section 503 of the Rehabilitation Act, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, which collectively, in short, prohibit discrimination and require affirmative action based on specific, enumerated characteristics. The agency and its procedures have evolved quite a bit in the last 10-15 years. However, while the OFCCP became much more effective in enforcing the Executive Order, little was done to have a significant impact on the rights of veterans and individuals with disabilities.

Recognizing this, the agency introduced new requ