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The language in the veterans regulations is as follows: 41 CFR 60-300.44(b) Review of personnel processes. The contractor shall ensure that its personnel processes provide for careful, thorough, and systematic consideration of the job qualifications of applicants and employees who are known protected veterans for job vacancies filled either by hiring or promotion, and for all training opportunities offered or available. The contractor shall ensure that when a protected veteran is considered for employment opportunities, the contractor relies only on that portion of the individual’s military record, including his or her discharge papers, relevant to the requirements of the opportunity in issue. The contractor shall ensure that its personnel processes do not stereotype protected veterans in a manner which limits their access to all jobs for which they are qualified. The contractor shall periodically review such processes and make any necessary modifications to ensure that these obligations are carried out. A description of the review and any necessary modifications to personnel processes or development of new processes shall be included in any affirmative action programs required under this part. The contractor must design procedures that facilitate a review of the implementation of this requirement by the contractor and the Government (Appendix C of this part is an example of an appropriate set of procedures. The procedures in Appendix C are not required and contractors may develop other procedures appropriate to their circumstances.) [Appendix C reads as follows:] The following is a set of procedures which contractors may use to meet the requirements of § 60–300.44(b): 1. The application or personnel form of each known applicant who is a protected veteran should be annotated to identify each vacancy for which the applicant was considered, and the form should be quickly retrievable for review by the Department of Labor and the contractor’s personnel officials for use in investigations and internal compliance activities. 2. The personnel or application records of each known protected veteran should include (i) the identification of each promotion for which the protected veteran was considered, and (ii) the identification of each training program for which the protected veteran was considered. 3. In each case where an employee or applicant who is a protected veteran is rejected for employment, promotion, or training, the contractor should prepare a statement of the reason as well as a description of the accommodations considered (for a rejected disabled veteran). The statement of the reason for rejection (if the reason is medically related), and the description of the accommodations considered, should be treated as confidential medical records in accordance with § 60–300.23(d). These materials should be available to the applicant or employee concerned upon request. 4. Where applicants or employees are selected for hire, promotion, or training and the contractor undertakes any accommodation which makes it possible for him or her to place a disabled veteran on the job, the contractor should make a record containing a description of the accommodation. The record should be treated as a confidential medical record in accordance with § 60–300.23(d). PLEASE NOTE that while much of the language cited above for section 300.44(b) is paralleled in the disability regulations at 41 CFR 60-741.44(b), there is no Appendix C in the disability regulations. The disability regulations include an "encouragement" to make sure information and communications technologies are accessible to individuals with disabilities that is not found in the veterans regulations. Bottom line: there are many different actions you should consider taking in this review of personnel policies and practices. There is no one set of required actions, but you should be able to show some effort was made to do a systematic review of personnel policies and practices that may affect protected veterans or individuals with disabilities. There is also no specific format for the assessment review, but any document you create should focus on the specific actions taken by your organization to facilitate the employment of protected veterans and individuals with disabilities.
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.