January 2012
Recently, the Office of Federal Contract Compliance Programs (OFCCP) proposed revised regulations for "Affirmative Action Programs," or programs regulating the treatment of minority and disabled individuals by employers who have 50 or more employees and a government contract worth $10,000 or more.
Wessels Sherman will be submitting a comment to the OFCCP so that we may advocate for our clients and friends, and would like to provide our clients with the opportunity to express their opinions for use in the comment on the issues outlined below:
- Invitations to Self-Identify - Federal contractors must provide anonymous invitations to self-identify to all job applicants, and to all current employees at least once per year.
- 7% Utilization Goal for Disabled Employees - Federal contractors must set a goal of having 7% of their workforce be people with disabilities. If this goal is not met, they must explain why and provide a plan to reach the 7% goal the following year.
- 2% Subutilization Goal for Severely Disabled Employees - Federal contractors must set a goal of having 2% of their workforce be people with "severe" disabilities (note - the 2% would count towards the 7% utilization goal discussed in [2]). If this goal is not met, they must explain why and provide a plan to reach the 7% goal the following year.
If enacted, these rules will have a significant impact on covered employers - potentially resulting in increased administrative expenses and decreased discretion over workforce development. Anyone with questions, concerns, and/or suggestions should contact WS Attorney Peter E. Hansen via phone at (262) 560-9696 or email at pehansen@wesselsherman.com by Wednesday, February 01, 2012 so that we may express them directly to the OFCCP.
