Award would recognize contractors that “that ensure equal employment opportunity, foster employment opportunities for individuals with disabilities, and have achieved a level of excellence in their compliance with Section 503”
In support of its recent Directive 2018-06 [Contractor Recognition Program] OFCCP has proposed to implement an Excellence in Disability Inclusion Award.
Contractors winning the award will earn a two-year moratorium on compliance evaluations for the winning establishment. The criteria for eligibility include:
• Development and implementation of current AAPs.
• No unresolved violations of laws enforced by the OFCCP, which includes violations that are in litigation, in an open conciliation agreement, and in a pending compliance reviews.
• No adverse decisions by a court, Administrative Review Board, or Administrative Law Judge related to Section 503, EO 11246, VEVRAA or the Americans with Disabilities Act within the last three years and not currently under monitoring related to the same.
The application process would require eligible contractors to submit a nomination package, which would require a lengthy investment of time. Contractors that can show effective use of apprenticeship programs would be “favorably considered” and would receive additional points in the review process. Awards would be presented to two small contractors (total workforce of 100 or fewer employees) and two large contractors (total workforce of more than 100 employees). “Honorable mention” nominees would also be identified in both categories; however, these nominees would not be entitled to the compliance evaluation moratorium but would be required to participate in the post-award program activities identified below.
Contractors winning the award would be signing on to future commitments with the agency. For example, a winning contractor would have to participate in a public service announcement on the importance of compliance with the OFCCP’s regulations and “policy strategies and effective practices for increasing employment opportunities for individuals with disabilities.” Additionally, the winning contractor would be required to work with OFCCP and the Office of Disability Employment Policy “in a peer-to-peer mentoring program to support contractors as they seek to comply with OFCCP regulations” and “develop and/or provide input into the development of technical assistance, outreach, and model practices for use by other employers, including federal contractors.” Comments about the proposal are due by December 4, 2018. Comments can be submitted here.