The OFCCP has finalized one of its award programs.
The Office of Federal Contract Compliance Programs, in partnership with the Office of Disability Employment Policy, has announced one of its award programs for federal contractors. The Excellence in Disability Inclusion Award will recognize contractors who “go above and beyond to recruit, hire, retain, and advance individuals with disabilities in the workplace.”
The OFCCP will select two large contractors (total workforce of more than 100 employees) and two small federal contractors (total workforce of 100 or fewer employees) for the Gold Award, which comes with a three-year moratorium on compliance evaluations. In addition, up to 20 additional contractors will be recognized as Pacesetters, or honorable mentions.
Contractors must meet the following criteria to be eligible to receive the award.
- The establishment must have
- 50 or more employees,
- A federal contract of $50,000 or more, and
- Current and implemented affirmative action programs under Section 503 of the Rehabilitation Act, Executive Order 11246, and the Vietnam Era Veterans’ Readjustment Assistance Act (if the facility or parent company has a federal contract of $150,000 or more).
- The establishment must not have any unresolved violations of Section 503, Executive Order 11246, or VEVRAA.
- The establishment cannot have any adverse decisions during the past three years by a court, Administrative Review Board, or Administrative Law Judge related to violations of Section 503, Executive Order 11246, VEVRAA, or Title I of the Americans with Disabilities Act.
According to the nomination package, contractors applying for the award must agree "to participate in a video success story on the importance of contractor compliance with OFCCP’s regulations and that generally aligns with Office of Disability Employment Policy’s (ODEP) broad goal of developing and validating policy strategies and effective practices for increasing employment opportunities for individuals with disabilities." Those contractors selected for an award must cooperate with the OFCCP and the ODEP in a "Year of Engagement," which includes speaking engagements and appearances, as well as a two-day "Policy Academy."
You may remember our blog post about this proposed award late last year. Although the final program is similar to the proposal, some changes of note include the following:
- Winners of the Gold Award will receive a three-year moratorium on compliance evaluations for the winning establishment instead of the two-year moratorium that was initially proposed.
- There is no longer an indication that contractors who demonstrate use of apprenticeship programs in their initiatives will be “favorably considered” in the review process.
Contractors who are interested in competing for the award must submit an application and nomination form. Completed applications are due by Saturday, August 31, 2019.
Our Affirmative Action Alert blog focuses on the latest news and topics affecting federal contractors and subcontractors and their compliance with affirmative action and other employment-related laws and regulations. With breaking news, quick updates, and headlines on the Office of Federal Contract Compliance Programs and affirmative action issues, this blog is a great resource for in-house counsel, HR managers, and other compliance professionals. Our blog is a companion to Constangy’s Affirmative Action newsletters, which address significant legislative, regulatory, and administrative proposals and changes. Subscribe to both to stay current on these important topics!