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Client Alert: OFCCP posts new FAQs clarifying Section 503 and VEVRAA regulations




By Chase Fisher

Notably, contractors who elect to incorporate the required Equal Opportunity clauses by reference may now combine the clauses for Executive Order 11246, Section 503 and VEVRAA into one bolded clause.  The FAQs provide the following sample: “This contractor and subcontractor shall abide by the requirements of 41 CFR §§ 60-1.4(a), 60-300.5(a) and 60-741.5(a). These regulations prohibit discrimination against qualified individuals based on their status as protected veterans or individuals with disabilities, and prohibit discrimination against all individuals based on their race, color, religion, sex, or national origin. Moreover, these regulations require that covered prime contractors and subcontractors take affirmative action to employ and advance in employment individuals without regard to race, color, religion, sex, national origin, protected veteran status or disability.”

Any existing federal contractor or subcontractor, including those who are considering becoming such, should carefully review the changes set to occur on March 24, 2014 and by their next AAP year on or after that date.  While the FAQs do not answer everything, they help clarify some of the confusion surrounding the changes.  For any additional questions you may have regarding the upcoming OFCCP changes and necessary compliance, please contact Chase Fisher or Howard Kastrinsky.


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