There are 2 types of construction contractors: direct federal construction contractors (for example, building a federal courthouse, FEMA construction contract) and federally-assisted construction contractors (for example, building a road or bridge with DOT funds). Only direct federal construction contractors and their subcontractors have disability AAP obligations under Section 503 of the Rehabilitation Act and protected veteran AAP obligations under VEVRAA. The dollar amount to trigger Section 503 AAP obligations is $50,000. The dollar amount to trigger VEVRAA AAP obligations is $150,000. If you are only a federally-assisted construction contractor, you do not need disabilty or protected veteran AAPs. You would only need to maintain evidence of your compliance with the 16 steps, but keep in mind that there are significant record keeping obligations associated with applicant tracking and the selection process that arise out of other regulatory obligations and are implicit in step 7(k) that requires you to validate tests and other selection processes in accordance with 60-3.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.