Federal contractors and subcontractors have new numbers to keep in mind when evaluating their compliance obligations. The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has officially updated the jurisdictional thresholds for the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) and Section 503 of the Rehabilitation Act.

These adjustments are part of a routine inflationary review required by the Federal Acquisition Regulation (FAR). Here is what you need to know:

The Updated Thresholds

The dollar amount of a federal contract or subcontract that triggers OFCCP jurisdiction has increased as follows:

• VEVRAA (Protected Veterans): The threshold has increased from $150,000 to $200,000.
• Section 503 (Individuals with Disabilities): The threshold has increased from $15,000 to $20,000.

If your contract or subcontract falls below these specific dollar amounts, you are not subject to the affirmative action and non-discrimination requirements of that specific law.

However, it is important to remember that for Section 503, while the threshold for basic coverage is now $20,000, the requirement to maintain a written Affirmative Action Program (AAP) for individuals with disabilities applies only to contractors with 50 or more employees and a contract of $50,000 or more. For VEVRAA, written AAPs for veterans are required at the $200,000 basic threshold, when the contractor or subcontractor has 50 or more employees.

What to Do Next

1. Review Current Contracts: Work with your procurement or legal departments to determine the exact value of your federal contracts and subcontracts.
2. Update Internal Documentation: Ensure that your HR and compliance teams are aware of the new limits when determining which regulations apply to specific business units or subsidiaries.
3. Verify Language in Subcontracts: Ensure that the mandatory “equal opportunity clauses” included in your subcontracts reflect the correct legal citations and applicable thresholds.

Staying proactive in monitoring these changes will help your organization maintain adherence to Department of Labor standards and mitigate potential risks. For additional guidance, visit the official OFCCP Jurisdictional Thresholds page or consult your legal counsel.

THIS COLUMN IS MEANT TO ASSIST IN A GENERAL UNDERSTANDING OF THE CURRENT LAW AND PRACTICE RELATING TO OFCCP. IT IS NOT TO BE REGARDED AS LEGAL ADVICE. COMPANIES OR INDIVIDUALS WITH PARTICULAR QUESTIONS SHOULD SEEK ADVICE OF COUNSEL.