Recent OFCCP Audit Focus: VEVRAA and JVA Compliance

As the OFCCP continues to aggressively audit contractors on issues that were not as thoroughly investigated in the past, contractors must be aware of the current regulations to be prepared in the likely event an audit letter arrives on their desk. The Jobs for Veterans Act (JVA) and Vietnam Veterans’ Readjustment Act (VEVRAA) amendments in 2003 created a shift in focus from OFCCP, particularly related to job posting compliance. The JVA amendments made three significant changes to the Affirmative Action requirements of VEVRAA:

1. The threshold dollar amount for contracts raised from $25,00 to 100,000 for contractors that must be covered with an affirmative action plan
2. The list of covered veterans has been redefined from special disabled veterans, newly separated veterans, other protected veterans, and veterans of the Vietnam era to disabled veterans, recently separated veterans, other protected veterans, and Armed Forces service medal veterans.
3. The cut-off date for following the new regulations is December 1, 2003. Therefore, if a contractor had a contract with $25,000 or more before December 31, 2003 and one of $100,000 or more after December31, 2003 the contractor must comply with both.

With the new amendments and overhaul of regulations, auditors are no longer accepting a generic list of outreach programs to verify compliance. Contractors are now expected to prove to the OFCCP that they are making good faith efforts to place veterans into their workforce by showing detailed documentation of all programs being used to attract veterans. Furthermore, contractors are responsible for being able to determine which programs are working and which programs are not working in order to abandon any programs that don’t have an impact. The intent is to show focus on efforts that do demonstrate results. To stay proactive with their affirmative action plan with regards to veteran recruitment, contractors can use specific sites targeted towards reaching veterans:

The following links provide free job postings for employers aiming to attract veterans:
• http://www.hirepatriots.com
• http://www.hireheroesusa.org
• http://www.jobarsenal.com
• http://www.nvf.org
• http://www.militaryconnection.com

The following links provide resources such as career events and priced job postings for employers aiming to attract veterans:
• http://www.hirevetsfirst.dol.gov
• http://www.edd.ca.gov
• http://www.recruitmilitary.com
• http://www.military.com
• http://www.gijobs.com
• http://www.jobbankinfo.org
• http://www.usajobs.com
• http://www.militaryjobzome.com
• http://www.militarystars.com
• http://www.hireahero.com
• http://www.jobs.vetfriends.com