Staffing agencies which are subcontractors and meet the jurisdictional thresholds under Executive Order 11246, Section 503 of the Rehabilitation Act, and VEVRAA (see https://www.dol.gov/sites/dolgov/files/ofccp/posters/Infographics/files/JurisdnThresholds-7_ENGESQA508c.pdf) are required to follow regulatory requirements for their employees. Furthermore, one violation often found by staffing agencies which undergo OFCCP compliance reviews is lack of records. (See https://www.dol.gov/sites/dolgov/files/ofccp/CAGuides/files/Quick-Tips-503-WEB_080119_CONTR508c.pdf#:~:text=Understanding%20OFCCP%E2%80%99s%20Recordkeeping%20Requirements.%201%20Outreach%2C%20and%20positive,applicants%20hired%20%2841%20CFR%2060-741.44%28k%29%29.%20%20HowLong.%20).
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.