On September 11, 2019 the OFCCP held a webinar to provide information about their new Section 503 Focused Reviews. In August of 2018, the OFCCP issued the Directive announcing these new Focused Reviews. In March 2019, the OFCCP notified 500 contractors they will be scheduled for the Section 503 Focused Review through their Corporate Scheduling Announcement Letter (CSAL). The OFCCP just completed training for their staff in August on how to conduct the reviews. Listed below are some interesting highlights from the webinar:
- The Focused Section 503 Reviews will include a mandatory on-site visit.
- The OFCCP will be posting sample on-site questions on their website.
- A current AAP for Minorities and Women will be required to be submitted, but only for the purpose of providing job groups – the agency will not be analyzing all aspects of the AAP for Minorities and Women.
- The OFCCP is currently working on a new form for the self-identification of individuals with a disability (IWD).
- The OFCCP advises contractors to utilize their Regional Outreach Coordinator (ROC) which is available in each region to get resources on outreach to IWD organizations.
- Another “best practice” is to have a centralized reasonable accommodation policy and to appoint a “Chief Accessibility Officer” to ensure consistency and follow-through on providing accommodations.
- Recruiters should not be giving preferences to IWDs in the hiring process, but we learned if your human resources department knows an employee has a disability, but the employee did not self-identify, you can mark them as an IWD and have a human resources representative sign the form in order to track them in your system. However, the OFCCP also said not to assume someone is disabled if they request an accommodation because it might be a temporary disability.
- The OFCCP has developed a website specific to Section 503 for additional resources. It can be found here https://www.dol.gov/ofccp/Section503-FocusedReviews/index.html.
For more information and history on Section 503 Focused Review Audits, please read our related news story at http://malyconsulting.com/2019/06/18/ofccp-resources-for-503-focused-review-audits/.