The OFCCP recently released a new clarification FAQ relating to reporting requirements for Items 9, 10, 13 and 14 in the new Itemized Listing. This clarification is specific to those federal contractors who are six months or more into their affirmative action plan year when they receive an audit scheduling letter.
Clarification for Items 9 & 13
To stay in compliance, contractors can do one of two things to meet their reporting requirements for Items 9 and 13, which are applicable to Section 503 and VEVRAA:
- ‘…compute the employment activity totals for Individuals with Disabilities and for Protected Veterans during the first six months of the current AAP year and…submit that information…,’ or
- ‘…contractor must provide the records showing the number of job openings, applicants, jobs filled, and hires that would permit OFCCP to compute the totals.’
Clarification for Item 10
For Item 10–applicable to Section 503–contractors are, ‘expected to perform a partial year utilization analysis for Individuals with Disabilities in each job group or the entire workforce, as appropriate…’ or provide the OFCCP with the data so they can perform the analysis themselves.
Clarification for Item 14
For Item 14–applicable to VEVRAA–contractors must only, ‘…submit documentation of the hiring benchmark that it adopted. This includes documenting the results of the application of the five-factor method if the contractor sets its own benchmark.’ An important clarification to note is that, ‘…the contractor does not have to analyze or compare hiring of protected veterans to the adopted benchmark.’
To read these new FAQs, you can visit the DOL’s official page.
