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With OFCCP currently scheduling VEVRAA Focused Reviews, federal contractors need to be prepared for the new audits. These specific reviews center on affirmative action compliance for protected veterans as required by the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA).

Back in November of 2019, OFCCP published the new Corporate Scheduling Announcement List (CSAL) of 500 establishments selected for a VEVRAA Focused Review. These federal contractors and subcontractors are now receiving scheduling letters to inform them of the date of their review and to request certain information:

  1. Copy of your Executive Order 11246 Affirmative Action Program (AAP)
  2. Copy of your VEVRAA AAP
  3. Results of your evaluation of the effectiveness of outreach and recruitment of qualified protected veterans
  4. Documentation of data for applicants and hires for the preceding AAP year and at least the first six months of your current AAP year (if six months or more into the your AAP year)
  5. Documentation of the hiring benchmark you established, including methodology used if utilizing the five factors
  6. Copy of your collective bargaining agreements with documents you prepared (policy statements, employee notices, etc.) that implement, explain, or elaborate
  7. Copies of reasonable accommodation policies and documentation of accommodation requests received, as well as the resolution (if applicable)
  8. Most recent assessment of personnel processes, including descriptions of the review and actions taken based on the assessment
  9. Most recent assessment of physical and mental qualifications, including the schedule for the review and actions taken based on the assessment

OFCCP Starting VEVRAA Focused Reviews: What You Need to Know

Each establishment has only 30 days to submit all of this data once they receive their scheduling letter. This time constraint is why it is vital employers are consistently tracking and documenting the above information. On top of submitted this data, contractors need to prepare for their on-site VEVRAA Focused Review. For a comprehensive guide on what is expected during the audit, employers should review the VEVRAA Compliance Audit Checklist.

Keep in mind, due to COVID-19, the on-site visit will likely be done virtually. This has been the process for the Section 503 Focused Reviews. These “virtual on-sites” should be treated with the same level of importance and detail as any live audit review.

If you have more questions or concerns, you can find many valuable resources. OFCCP released an FAQ earlier this year for the VEVRAA Focused Reviews. You can also find insights on preparing for these reviews from the OFCCP’s veteran outreach event or head to the Department of Labor (DOL) website for more information.

Should your organization need more in-depth assistance or guidance with your compliance efforts, you can connect with an expert at Circa today.

Author

Tim Muma
Product Marketing Lead
Circa

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