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OFCCP Adds Two New Informative Section 503 Resources

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Sample on-site guide and SCER report added to OFCCP Section 503 focused review webpage

OFCCP added the following resources to their Section 503 Focused Reviews webpage.

The extensive On-Site Guide outlines the pre-onsite and onsite procedures for conducting a Section 503 focused review. It communicates the information that will be requested in advance of the review and identifies the steps, processes, documentation, forms, etc. it will review during the on-site. It also provides information about interviews relating to special emphasis groups, reasonable accommodations committees/boards, employees, short-term disability coordinators, and individuals responsible for outreach, recruitment, and screening candidates. The guide indicates that CO’s “should review personnel files for employees who indicated that they requested a reasonable accommodation.” “Specifically, the CO should review salary and promotion history to determine if disparities exist between them and similarly situated employees who have not requested a reasonable accommodation.”

The SCER is the internal document the CO is required to complete during the focused review. The SCER report for Section 503 focused reviews is similar to the SCER for regular compliance reviews; however, has a section which identifies the geographic area (SMSA) with race, gender, veteran and disability statistics. It is unclear how the CO obtains the data for those fields. In the “Preparation” section, the CO must address the contractor’s “past performance related to Section 503 with OFCCP, current complaints with EEOC or other DOL agencies and any collaboration with ODEP or State Vocational Rehabilitation organizations.” When the CO evaluates whether the 7% goal was met, they must also identify the “steps the contractor took to determine if impediments exist, and the action-oriented programs developed to correct any identified problem areas.” Similarly, in evaluating outreach and recruitment efforts, the CO is directed to “consider if the contractor listed each effort including the name and date, and indicate whether the specific event was effective and why it was considered effective.”

If you are anticipating a focused review or just want to be prepared for a future review, we highly recommend reviewing these tools in more detail.

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