November is here and the federal contractor community is bracing for a new round of CSALs. Recall that at the last ILG National Conference, OFCCP announced its plans to release another audit scheduling list in November, in time for Veterans Day, that will include VEVRAA Focused Reviews. We've also heard OFCCP say that this list will include Higher Education institutions. This is separate from the scheduling list that it plans to release in Spring of 2020, which will include "Promotions Focused Reviews."
What will OFCCP look for in the VEVRAA Focused Reviews? We're hoping to learn more about this next week at the Veteran Outreach event that OFCCP is co-hosting with the Veterans Employment and Training Service (VETS). OFCCP will be speaking on “Focused Compliance Reviews under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).” LocalJobNetwork will be at this event and we'll be sure to post updates on this blog soon after.
What can you do to prepare in the meantime? Understanding your obligations under VEVRAA is a good first step. Below is a high level summary that you should review with your HR and talent acquisition teams to ensure that you are compliant. You can also download our Compliance Self-Audit Checklist for a comprehensive list across all three regulations.
- List your employment openings with the appropriate employment service delivery system (ESDS).
- Undertake outreach to attract, recruit, and hire protected veterans.
- Set an annual hiring benchmark for protected veterans. You can establish this using the national percentage of veterans in the civilian labor force, which is currently at 5.9%.
- Invite applicants to voluntarily self-identify their status as a protected veteran at the pre-offer and post-offer stages of your hiring process.
- Document that you are collecting and analyzing the following data annually as part of your AAP:
- The total number of applicants for all jobs.
- The total number of applicants hired.
- The number of applicants who self-identified as protected veterans or are otherwise known as protected veterans.
- The number of protected veteran applicants hired.
- The total number of job openings and total number of jobs filled.
- Conduct an annual assessment of your outreach efforts to protected veterans to determine if efforts are effective or ineffective. If efforts are ineffective, make sure you took action-oriented steps to remedy issues and improve results.
- Ensure that you are including an EEO tagline in your job advertisements and incorporating the Equal Opportunity clause in all of your subcontracts.