Reviewing the updated Vets requirements

By Christine Anthony, Analyst, Biddle Consulting Group

OFCCP issued a Final Rule (Code of Federal Regulations [CFR] § 60-300) effective September 7, 2007 which addressed the Affirmative Action Plan (AAP) requirements and mandatory listing requirements for veterans.
The Jobs for Veterans Act (JVA) increased the threshold of coverage of a single contract from $25,000 to $100,000 or more for contracts that are owned or modified on or after December 1, 2003. The AAP content for contracts under the new threshold must contain the following: policy statement, review of personnel process, reasonable accommodation to physical and mental limitations, policy to prevent harassment, external dissemination of policy, internal dissemination policy, audit and reporting system, responsibility for implementation, and training policy. These are the same requirements under CFR § 60-250.
The classification of veterans has changed. The current classifications are: Armed Forces Service Medical Recipient, Disabled Veterans (service connected), Recently Separated Veterans (past 3 years), and Other Protected Veterans. The classification of Vietnam Era Veteran has been elimination. However, it is probable that those falling under this classification will fit within the parameters of at least one of the new classifications. The Newly Separated Veterans has been redefined to include veterans who have separated from service within the past three years rather than the past year as the previous definition stated. Finally, the Disabled Veterans category has been expanded to include all veterans with a service-related disability, regardless of the disability rating.
Several contractors may find themselves with the need to comply with both sections of the CFR. In that case, the contractor can choose to create two AAPs or they may develop a single AAP following CFR § 60-300. Please see Appendix B of the Final Rule for further guidance on how to solicit veteran status.
Changes have also been made to the mandatory job listing requirements. Contractors falling within the contract thresholds must list all job openings with the state workforce agency job bank as well as a local employment service delivery system. Contractors must list in the notification where the job opening is located. The job listing requirements applies to all employment openings with the exception of temporary position of three days or less, positions filled internally, or executive/senior level management positions. It is important for contractors to know that they are responsible for all third party recruitment agencies efforts to comply with the regulations.