OFCCP’s Veterans’ Focused Reviews are Here, Along With Resources for Covered Contractors

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
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Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

In August 2018, the Office of Federal Contract Compliance Programs (OFCCP) informed the contractor community of its intent to conduct compliance reviews focused solely on the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA) regulations.  Since Directive 2018-04 was published, OFCCP released its 2019 Corporate Scheduling Announcement Letter (CSAL) supplement, which identified 500 contractor establishment locations for future VEVRAA focused reviews.

Following up on OFCCP Director Craig Leen’s July 6, 2020, comments at the National Industry Liaison Group’s 2020 Virtual Conference, on August 4, 2020, OFCCP notified contractors that those on the CSAL list can expect VEVRAA focused review scheduling letters any day. Thus, now is a great time to visit—or revisit—the resources that OFCCP has published to assist in complying with VEVRAA obligations and navigating the upcoming focused reviews.

OFCCP created a VEVRAA landing page on its website, which offers a number of compliance assistance resources, including:

In addition, OFCCP has provided FAQs for military spouses. The agency issued Directive 2020-01 to reiterate VEVRAA’s extension to military spouses and other individuals who have a familial, business, social, or other relationship or association with a protected veteran. The FAQs for military spouses provide background about VEVRAA and who is covered, and resources to assist with the recognition of state-issued licenses or certificates that may be required for a military spouse’s job.

Contractors that are subject to the provisions of VEVRAA and/or who find their corporate headquarters, establishments, or functional unit locations on the current CSAL list for a VEVRAA focused review may want to consider reviewing OFCCP’s resources to ensure their obligations are being met. Even in the absence of a focused review, covered contractors may want to start preparing to show compliance with VEVRAA during establishment or Functional Affirmative Action Program (FAAP) compliance reviews. If not on the current CSAL list, contractors should still be aware that additional VEVRAA focused reviews may be issued in a new CSAL list before the end of the year.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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