The major overhaul six years ago by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) of its regulations implementing Section 503 of the Rehabilitation Act (Section 503) and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (Section 4212) established new and additional recordkeeping, affirmative action, and other compliance-related requirements, including numerical hiring targets for veterans and numerical utilization goals for persons with disabilities, that added significantly to the compliance burden of covered federal contractors.

Since then, the agency has placed greater emphasis on scrutinizing contractors’ Section 503/4212 compliance efforts, including institution last year of new Section 503 “focused review” compliance evaluations, during which OFCCP Compliance Officers (COs) have been routinely issuing extensive follow-up requests for information (RFIs) after receiving the desk audit materials.

Members of the Center for Workplace Compliance (CWC) can read more here.