FAQs clarifies the handling of partial year totals in response to items 9 and 13
OFCCP added the following new FAQ on the compliance evaluation scheduling letter and itemized listing related to VEVRAA and Section 503.
Q: Do contractors have to compute and submit partial year totals in order to respond to items 9 and 13 in the Itemized Listing that request documentation of the computations or comparisons called for in the Section 503 regulations at 41 CFR 60‐741.44(k) and in the VEVRAA regulations at 60‐300.44(k)?
A: The regulations at 41 CFR 60‐741.44(k) and 41 CFR 60‐300.44(k) require a contractor to compute and document annual totals for the number of job openings, applicants, jobs filled, and hires who self‐identified as individuals with disabilities, and the number of applicants and hires who self‐identified as protected veterans. In order to compute the annual totals for VEVRAA contractors must, on an ongoing basis, collect and keep records on the number of applicants who self‐identified as protected veterans; the total number of job openings and total number of jobs filled; the total number of applicants for all jobs; the number of protected veteran applicants hired; and the total number of applicants hired. Contractors must collect the same information for individuals with disabilities for their annual totals. Based on these requirements, it should be fairly easy for contractors to compute the employment activity totals for individuals with disabilities and for protected veterans during the first six months of the current AAP year and to submit that information in response to the Itemized Listing. If, however, a contractor has not computed, or is unable to compute, these totals for the first half of the current AAP year, the contractor must provide the records showing the number of jobs openings, applicants, jobs filled, and hires that would permit OFCCP to compute the totals.
OFCCP reminds contractors that the Scheduling Letter, which includes its Itemized Listing, creates a legal obligation to provide the information, in accordance with OFCCP’s authority to conduct compliance evaluations.
Founded in 1998, OutSolve has evolved into a premier compliance-driven HR advisory firm, leveraging deep expertise to simplify complex regulatory landscapes for businesses of all sizes. With a comprehensive suite of solutions encompassing HR compliance, workforce analytics, and risk mitigation consulting, OutSolve empowers organizations to navigate the intricate world of employment regulations with confidence.
Featured Posts

What Is an I-9 Authorized Representative?

outRageous HR Podcast: What to Do When ICE Knocks: How to Prepare
Related Posts

State Pay Data Reporting Requirements: What You Need to Know

If you’re in Human Resources (HR) and your company operates in multiple states, then chances are your plate is already full trying to keep up with...

Bye-Bye American Pie: OFCCP to Slip Beneath the Waves on September 30, 2025

OutSolve has invited John C. Fox, Esq. as a guest blogger providing legal insights on EEO and compliance issues. The views expressed in his posts are...

What Happens During a Form I-9 Audit by ICE or DHS?

This article is part of an ongoing legal series designed to provide insight and practical guidance on current and emerging workplace compliance...