The revised veteran and disability regulations state that federal contractors and subcontractors must collect information on applicants, "hires," job openings, and jobs filled. These requirements are found at 41 CFR sec. 60-300.44(k) for veterans and 41 CFR sec. 60-741.44(k) for individuals with disabilities. A reading of those two sections of the regulations does not require that data be broken out by affirmative action job group. While I expect OFCCP would be happy to receive data by job group, you would be within your rights under the regulations to submit information at the AAP plan level. The only portion of the revised veteran and disability regulations that refers to job groups is the utilization goal section in the regulations for individuals with disabilities. (41 CFR sec. 60-741.45) Note that the utilization goal applies to a review of the workforce, NOT a review of applicants or hires. It will be interesting to see how much confusion there is among compliance officers about what must be submitted under sections 300.44(k) and 741.44(k). Good luck with your compliance review.

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.