Veterans & Individuals with Disabilities
Because the regulations covering protected veterans and individuals with disabilities are so similar, many contractors choose to combine the written Affirmative Action Program for Protected Veterans and Affirmative Action Program for Individuals with Disabilities (“AAPs”). These programs contain the policies and procedures for non-discrimination and affirmative action for:
- Disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans (collectively referred to as “protected veterans”) in accordance with the regulations issued pursuant to the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended by the Jobs for Veterans Act of 2002 (38 U.S.C. 4212, or VEVRAA and JVA) (the “Act”).
- Individuals with disabilities. This policy and the implementing procedures are in accordance with regulations issued pursuant to Section 503 of the Rehabilitation Act of 1973, as amended.
Typical sections include:
- Program Available for Inspection
- Pre-Offer Invitation to Self-Identify and Participate
- Post-Offer Invitation to Self-Identify and Participate
- Policy Statement
- Implementation Responsibilities
- Review of Personnel Processes
- Review of Physical/Mental Job Qualifications
- Reasonable Accommodation
- External Dissemination of Policy, Outreach, and Positive Recruitment
- Assessment of External Outreach and Recruitment Efforts
- Internal Communication of Policy
- Audit and Reporting System
- Data Collection
- Record Keeping
In addition, each year, contractors are required to establish a facility-wide hiring benchmark for protected veterans. Contractors can either use the OFCCP published estimate of total veterans in the civilian labor force, or establish an individualized hiring benchmark using the OFCCP’s five factor method.
For individuals with disabilities, contractors are required to establish 7% utilization goals by job group at each AAP facility. If the total U.S. workforce is < 100, employers can use a single, company-wide goal. In addition, the AAP for individuals with disabilities must also include sections on Identification of Problem Areas and Action-Oriented Programs.
Please note, these AAPs are public documents and must be made available to any employee or applicant who wishes to view them.