Berkshire Associates’ 2010 Enforcement Agency Updates: Outreach, Reporting, and Monitoring of Affirmative Action Obligations for Covered Veterans

The Office of Federal Contract Compliance Programs’ (OFCCP) 2010 agenda includes publishing a Notice of Proposed Rulemaking (NPRM) that would revise the regulations in 41 CFR Parts 60-250 and 60-300. Both of these impact the nondiscrimination and affirmative action provisions of VEVRAA. The NPRM would amend the regulations to strengthen the affirmative action requirements by requiring federal contractors and subcontractors to conduct more substantive analyses of recruitment and placement actions taken under VEVRAA for covered Veterans. It would also require the use of numerical targets to measure the effectiveness of affirmative action efforts.

In July 2010, the OFCCP submitted to the Office of Management and Budget its proposed rule. A 2010 audit trend requesting copies of the most recently filed Vets 100/ 100A form by contractors under desk audit is in line with this regulatory agenda. The Vets report is anticipated to become a standard item in the desk audit letter.

To find out more and to make sure your company is meeting recent compliance changes, please contact Berkshire Associates at 800.882.8904 or email bai@berkshireassociates.com.