Wednesday, October 24, 2012

Welcome DEAM 2012 Conference Attendees!

Welcome DEAM 2012 Conference Attendees

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Thursday, October 11, 2012

Enforcement Update


The ever-changing landscape of compliance and enforcement action between the Office of Federal Contract Compliance Programs (OFCCP) and the federal contractor community has long been a point of contention as the proverbial ‘carrot’ seems to endlessly change between a variety of levels in the agency.  While understanding and anticipating these changes is critical to limiting liability, it is the most simple actions which arguably land contractors in hot water as many fail to adequately maintain processes required under federal regulation.  These failures may ultimately result in the agency moving toward conciliation agreements, litigation, or debarment as the worst case scenario. 

The purpose of this news feed is to serve as a reminder to review your Annual Action Checklist and verify all items listed have been accomplished.  It should be noted that there has been a recent upswing in Notices of Violations and Conciliation Agreements in the federal contractor community pertaining to Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, as amended, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, and the implementing regulations at 41 CFR Chapter 60.

What does it all mean?  First, make sure you are listing ALL employment openings covered by your Affirmative Action Program with the local employment service office of the state employment security agency, as required by the Equal Opportunity Clauses at 41 CFR 60-250.5 and 60-300.5 (excluding executive and senior management positions, positions filled from within the organization, and positions lasting less than three days).  Second, ensure your organization is undertaking appropriate outreach and positive recruitment activities that are reasonably designed to effectively recruit qualified disabled veterans, recently separated veterans, other protected veterans, and Armed Forces service medal veterans, special disabled veterans and Vietnam era veterans as required by 41 CFR 60-250.44(f) and 60-300.44(f).  Third, ensure your organization is undertaking appropriate outreach and positive recruitment activities that are reasonably designed to effectively recruit qualified Individuals with Disabilities, as required by 41 CFR 60-741.44(f). 

Each of the recommendations above, including others can be found in your “Annual Action Checklist” sent as a part of your Confidential Package with your eAAP. 

Should you have any questions, Kairos professions are available to assist your company in answering questions pertaining to your listing, outreach, and reporting obligations required by federal regulations.

The content provided herein by Kairos Services, Inc. is for informational purposes only and not a substitute for professional advice.  The opinions expressed in this email service are the opinions of the individual author and may not reflect the opinions of the company or any individual professionals. You should seek independent advice from one of our professionals before acting upon any opinion or information contained in this mailer or our websites.