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OFCCP Offers Compliance Guidance For Focused Reviews

This year, OFCCP will for the first time be conducting focused reviews that hone in on contractors’ compliance with disability-related obligations under Section 503 of the Rehabilitation Act.  Because Section 503 compliance is a priority for OFCCP’s new leadership, contractors should undertake an internal audit to confirm that it complies with these obligations, including the compliance resources offered by OFCCP.

To help contractors prepare for focused reviews, on June 11, 2019, OFCCP posted a notice to contractors highlighting the resources and tools available to assist contractors in preparing for focused Section 503 reviews:

  • OFCCP’s Section 503 Focused Review webpage provides an array of links to additional information, including links to the relevant regulations in the Code of Federal Regulations, a copy of the form Scheduling Letter, factsheets, FAQ’s, and best practices.  Additional information regarding the Section 503 Review process can be found here

  • OFCCP also encourages contractors to use the resources made available by its partner agency, the Office of Disability Employment Policy (ODEP).  The ODEP provides webinars and training regarding the best practices for ensuring that employers create and maintain workplaces that are inclusive for people with disabilities.   The ODEP also provides a workplace accommodation toolkit, which provides guidance for employees and employers alike regarding the process of evaluating and providing an employee with a workplace accommodation.  

OFCCP expects that contractors to use these resources in developing its compliance programs and undertaking compliance self-audits.  During audits, OFCCP compliance officers are unlikely to be sympathetic to claims that a contractor was not aware of its compliance obligations under Section 503 and the Rehabilitation Act.  

© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume IX, Number 164


About this Author

Conne Bertram Government Contract Lawyer Polsinelli Law Firm

Connie focuses her practice on whistleblower, trade secrets, government contractors and employee mobility counseling and litigation. She frequently conducts confidential internal investigations involving executive-level employees, including alleged fraud, theft or misuse of company data, trade secrets, sexual harassment and code of conduct violations. She routinely counsels, investigates and litigates restrictive covenant and trade secrets disputes between employers and former employees.

Connie has defended complex whistleblower, trade secrets and restrictive...


Samuel Long is an associate in the Employment Disputes, Litigation and Arbitration practice group. Sam represents corporate clients and individuals in a variety of industry sectors in all aspects of labor and employment law, including representation before administrative agencies and litigation in state and federal court. Clients rely on him for valuable legal counsel as they face sensitive workplace issues. He has successfully defended clients against claims of discrimination, retaliation, and wrongful termination under state and federal statutes, including Title VII, FMLA, FLSA, ADA, and ADEA.

In addition, Sam also represents corporate management in labor disputes, including collective bargaining, arbitrations, and litigation before the National Labor Relations Board.

Prior to joining Polsinelli, Sam served as associate at a West Virginia office of a national law firm and as a legal clerk at the National Treasury Employees Union.