December 10, 2019

December 09, 2019

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VEVRAA and Section 503 Six Month Update Obligations Under the New Scheduling Letter

In FAQs released yesterday, OFCCP addressed requirements under the new Scheduling Letter for contractors to provide updated data collected pursuant to the revised Veterans and Individuals with Disability regulations if the contractor is more than six months into its current AAP plan year upon receipt of a Scheduling Letter.

OFCCP has previously indicated a contractor’s compliance with Subpart C of the new regulations does not go into effect until the contractor first updates its AAP after the March 24, 2014 effective date for the regulations.

Thus, contractors who are not yet subject to Subpart C of the new regulations are not required to provide the six month updates on itemized listing items under VEVRAA or Section 503 until they are more than six months into their plan year after they become subject to Subpart C.

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About this Author

Mickey Silberman, Labor and Employment law attorney, Jackson Lewis Law firm, Principal
Principal

Mickey Silberman is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. He is the Chair of the Jackson Lewis Affirmative Action & OFCCP Defense Practice Group and the Co-head of the firm’s Pay Equity Resource Group.

Mr. Silberman and the practice group annually prepare thousands of affirmative action plans for employers in all industries and throughout the country. During the past several years, Mr. Silberman has directed the defense of hundreds of OFCCP audits, including successful defense of Corporate Management (“glass ceiling”) Reviews....

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