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More Challenges for Federal Contractors as OFCCP Turns its Focus to Employees with Disabilities

December 21, 2011

By JON A. GEIER, MARIA A. AUDERO, EMILY NEWHOUSE DILLINGHAM & ZINA DELDAR

The Office of Federal Contract Compliance Programs ("OFCCP") issued proposed regulations on December 9, 2011 that would vastly expand federal contractors' affirmative action obligations towards individuals with disabilities. This Client Alert identifies seven key areas in which contractors' responsibilities will increase if the proposed regulations are finalized. The proposed changes will result in contractors needing to review and modify their recordkeeping, applicant tracking systems, personnel training, policies on reasonable accommodation requests, and other personnel processes.