In the last few years, there have been dramatic changes to the focus points at the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP). While for many years, OFCCP had little interest in issues concerning veterans and persons with disabilities, these groups are now at the forefront of OFCCP’s efforts. We know this is true in part because of the proposed regulations regarding veterans that were released in April of 2011 and the proposed regulations regarding persons with disabilities that were released in December of 2011.

Additional evidence of OFCCP’s focus on persons with disabilities can be found in the many inquiries OFCCP has made during recent affirmative action compliance reviews. OFCCP compliance officers:

  • Routinely ask for lists of employees with disabilities and the accommodations made for these employees.
  • Ask to interview employees with disabilities during the on-site portion of a compliance review.
  • Review policies and procedures to determine whether there are any impediments regarding persons with disabilities.
  • Examin