On November 8, 2019, the Office of Federal Contract Compliance (OFCCP) released its Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) Corporate Scheduling Announcement List (CSAL). The list includes 500 establishments designated for upcoming VEVRAA-focused reviews.
VEVRAA prohibits federal contractors and subcontractors from employment discrimination against protected veterans, and requires these employers take affirmative action to recruit, hire, promote, and retain veterans.
A VEVRAA-focused review is a comprehensive review of the contractors’ policies and procedures as they relate solely to VEVRAA. If selected for a compliance evaluation, contractors will need to be prepared with the following items:
- Submission of your complete AAP—including narratives for women, minorities, individuals with disabilities, protected veterans and statistical reports. The OFCCP will use the full AAP to obtain a clearer picture of organizational structure and how VEVRAA fits in with other affirmative action efforts—but they will not analyze data. However, if the OFCCP finds missing/insufficient data in the full AAP, they will take action to bring the contractor into compliance.
- A detailed review of your policies, procedures, and compliance related to VEVRAA.
- Verification the contractor conducted the required assessments of employment policies and tracked appropriate data.
- Review of outreach and good-faith efforts specifically for protected veterans.
- An on-site investigation and interviews with managers responsible for AA, EEO, and VEVRAA compliance.
Since the OFCCP will not mail advance notification to individual establishments, contractors are strongly encouraged to subscribe to OFCCP email updates to receive timely notifications of the release of CSALs and compliance assistance resources.
To help contractors prepare for the upcoming reviews, the OFCCP released a new VEVRAA-Focused Reviews landing page that includes best practices, protected veteran resources, answers to frequently asked questions, and other compliance assistance resources.
Source: OFCCP.gov; Michael Hyatt, Director, HR Government Affairs