The regulation you cite above is from the old version of the veterans regulations. This section of the regulations has been revised as part of the revisions released in September of 2013. Both former and current Section 300.44(f) is labeled "External dissemination of policy, outreach and positive recruitment". In both versions, this section primarily deals with outreach rather than dissemination of the policy statement per se. Revised section 60-300.44(f) and its parallel provision at 60-741(f) for individuals with disabilities have four components: (1) what OFCCP refers to as "required outreach efforts" (2) examples of possible outreach and recruitment activities (3) assessment of outreach efforts (4) documentation of outreach efforts. The only mandatory part within revised 300.44(f) is the following requirement found at 300.44(f)1(ii): -The contractor must send written notification of company policy related to its affirmative action efforts to all subcontractors, including subcontracting vendors and suppliers, requesting appropriate action on their part. In order to deal with this, companies are taking a number of approaches. Some are sending letters to vendors. Some are sending e-mails. Some are posting this information on websites. We have no formal guidance from OFCCP on what exactly is required in this regard, and thus we don't know what will be considered sufficient. My guess is that many OFCCP compliance officers will expect that companies have sent some kind of correspondence (whether electronically or via the mail) to each vendor. However, it's not clear this is truly required by the regulations, and we know that different organizations will take different approaches. Beyond that, companies have significant latitude in determining how they want to conduct their outreach. The assessment will be very important, though, and OFCCP is likely to mandate the use of certain outreach efforts if companies are unable to show they made outreach efforts or they were able to get effective results from their outreach efforts. It's worth noting that in the veterans regulations, and especially in the disability regulations, OFCCP is NOT looking for good faith efforts. The agency is looking for results. This means that outreach efforts that a company takes should be focused on producing results. The letter to vendors required in 300.44(f)1(ii) is a trivial but required part of this process.
