Subcontractor Responsibilities

Richie F. - August 8, 2017

In regards to notifying our subcontractors of our status as a federal contractor under the AAP this is a snippet of what I sent out to them:

“Our records indicate that you have provided goods and/or services to us according to established regulation thresholds under Section 503 of the Rehabilitation Act, as amended and the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA), as amended. Therefore, please be advised that your organization must also comply with the rules and provisions as specified by the US Department of Labor, Office of Federal Contract Compliance programs at CFR, Title 41, and Part 60-300 and 60-741.

We appreciate your support of our commitment to equal employment opportunity and request appropriate action on your part.”

What exactly are their responsibilities? What “appropriate action” do they need to take?

I just want to know in case they ask.

Thanks

1 Answer

Lisa Kaiser, Esq. Lawyer, The Kaiser Law Group, PLLC

Answered on August 8, 2017

If the company is a covered subcontractor (i.e., they are doing business with a federal contractor or subcontractor), then its obligations for compliance are like that of any covered contractor. Depending on the amount of the contract, of course, they must comply with the laws enforced by the OFCCP. This provision in the regulations puts the entity on notice that they are a covered subcontractor.

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.

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Subcontractor Responsibilities

Subcontractor Responsibilities

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