Taking a page from the Obamacare experience (keep the substance of controversial new policy changes intact, but delay implementation to allow those affected more time to adapt to the new policy regimen), OFCCP’s most recent Webinar (December 17, 2013) on VEVRAA and Section 503 has now “aligned” contractor obligations to comply with the so-called “Subpart C” requirements with the Affirmative Action Plan (AAP) implementation date. This position now firmly clarifies what had been differing written and oral statements about the issue of when contractors had to comply with Subpart C. The practical affect (and I will lay out some specific examples below) is to delay almost all (but NOT all) of the federal contractor community’s new VEVRAA and 503 affirmative action requirements to 2015 and some even into 2016. (See catalogue below of the several compliance obligations contractors MUST nonetheless implement on or before March 24, 2014). This is welcome relief to a weary federal contractor community.
Despite giving contractors a longer runway to comply, OFCCP is nonetheless strongly encouraging (but NOT requiring) those federal contractors who can earlier comply with the Subpart C requirements to do so effective on or after March 24, 2014…the ostensible “effective date” of the new Final regulations.
So, here is what has happened, and then the concrete (and surprising) examples…
THIS COLUMN IS MEANT TO ASSIST IN A GENERAL UNDERSTANDING OF THE CURRENT LAW AND PRACTICE RELATING TO OFCCP. IT IS NOT TO BE REGARDED AS LEGAL ADVICE. COMPANIES OR INDIVIDUALS WITH PARTICULAR QUESTIONS SHOULD SEEK ADVICE OF COUNSEL.
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