We are pleased to present the last in our “OFCCP Compliance Primer” series of memos designed to help new compliance professionals understand the affirmative action program (AAP) requirements enforced by the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP).

In this guide, we discuss the data collection analysis requirement, often referred to as the “data metrics,” and its relation to a federal contractor’s obligations regarding disability utilization and the veteran hiring benchmark under OFCCP’s revised Section 503/4212 regulations.

In our last guide, we discussed the culmination of the Executive Order 11246 AAP requirements for women and minorities: the evaluation of progress toward female and/or minority “placement rate goals” and the effectiveness (and sufficiency) of the company’s “good faith efforts.”

This final guide in the series turns to the required disability and veteran AAPs and, in a similar vein, looks at required reports and analyses to determine whether and to what extent additional outreach efforts for individuals with disabilities and/or veterans may be necessary to meet compliance requirements.

Members of the Equal Employment Advisory Council (EEAC) can read more here.