Regulations Refreshed: VEVRAA and Section 503 Regulations Mean New Challenges for Federal Contractors
By JON A. GEIER, MARIA A. AUDERO & HEATHER A. MORGAN
On August 27, 2013 OFCCP released its final regulations regarding the Vietnam Veterans Readjustment Assistance Act, as amended, and Section 503 of the Rehabilitation Act, as amended (collectively the “Final Rules”). The Final Rules substantially expand a contractor’s affirmative action obligations with respect to protected veterans and individuals with disabilities (“IWD”), and mandate many new record keeping requirements intended to permit OFCCP to evaluate contractor compliance. The Final Rules retain their historic organizational symmetry, and many of the new requirements are identical in the two sets of rules. In a number of areas, however, the application of the new obligations differs in critical ways.