A federal contractor is an organization who holds a contract directly from the federal government for the purchase, sale, or use of goods or services. State universities that receive federal contracts are covered. According to USASpending.gov, a direct payment is "a cash payment made by the federal government to individuals, private firms, and other private institutions." You should speak with counsel about your particular situation to determine what, if any, your organization is obligated to.

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.