It feels like we were just in the starting gate of compliance changes this year, and now the race is fully underway with compliance activities surrounding the revised regulations for Protected Veterans (PV) and Individuals with Disabilities (IWD). Let’s take a look at how the Office of Federal Contract Compliance Programs (OFCCP) is beginning to audit and enforce the new regulations.
Recently I heard a speaker indicate OFCCP is behaving as though the regulations have been in force for some time, when it has only been a little over three months since the implementation date. It is OFCCP’s recommendation that you comply as soon as practicable, however, according to Subpart C, the affirmative action plan (AAP) changes are not required until the beginning of your next AAP cycle. This means from the beginning of the compliance review, OFCCP’s expectations might be that you are fully in compliance with all the changes. Below are a few questions from OFCCP sent recently to a company whose scheduli