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.