Highlights from OFCCP’s Section 503 Focused Review Contractor Training Webinar
In the Spring of 2019, the Office of Federal Contract Compliance Programs (OFCCP) selected 500 federal contractors to undergo Section 503 Focused Reviews. Section 503 Focused Reviews are a new type of audit for the agency that requires OFCCP to conduct a comprehensive review of a contractor policies and procedures as they relate solely to Section 503. These reviews will also include an onsite investigation and interviews with managers and employees.
As a way of providing assistance to the 500 federal contractors that were selected for a 503 Focused Review, OFCCP held a webinar on September 11 to discuss the focused review process as well as the specific areas that will be examined during the review. In addition, OFCCP provided best practices that organizations could use to increase of the employment of individuals with disabilities. The webinar was conducted by Tina Williams, Deputy Director of Operations, and Nakisha L Pugh, Branch Chief of Functional Affirmative Action Programs. Highlights from the webinar include the following:
- Application Process: There will be an examination of the entire application process. The compliance officer will request a description of the application process and will review the applicant tracking system. They will also review both online and paper application forms to ensure accessibility and verify that the applications are kept separate from demographic survey forms. They will also ask to view screening questions, interview notes, and the physical space where applicants apply and are interviewed to assess accessibility of these areas. OFCCP will pay special attention to how organizations solicit information regarding disability status at the pre-offer stage, focusing on the form that is being used and anything the organization does to encourage applicants to complete the survey.
- On-Boarding/Orientation Process: In addition to the application process, the compliance officer will review the on-boarding process, including documentation such as the post-offer self-ID form, in order to assess accessibility. The agency is interested in how organizations solicit that information and if there is anything an organization does to encourage employees to complete the survey.
- Assessment of Outreach: OFCCP will thoroughly investigate the assessment of outreach activities that contractors made during the plan year. The compliance officer will look at the number of referrals and hires from each outreach source and evaluate if the sources used provided a good number of referrals and whether those referrals led to hires. The compliance officer will also inquire about the organization’s long term goals regarding outreach to individuals with disabilities and who the intended audience that the organization is trying to reach is. The presenters also mentioned the agency has Regional Outreach Coordinators (ROCs) who can connect contractors to community outreach organizations and provide other resources.
- Other Considerations: OFCCP outlined other considerations for organizations when looking at individuals with disabilities. They recommended that organizations consider forming a disability rights group, developing a disability rights policy, and showing a video about disability in order to get more employees to complete the self-ID form.
- Accommodation Process: Accommodations will be thoroughly reviewed. Specifically, the compliance officer will look at policies and procedures regarding the accommodation process. Interviews will be conducted with both employees and managers to ensure they know how to request an accommodation, as well as with managers to ensure they know how to handle requests for accommodation. The compliance officer will want to know what accommodations were requested, what were granted, what were denied, and who was involved in the decision-making process.
- Best Practices: OFCCP suggested best practices included creating a centralized accommodation process, getting buy-in from top leaders in the organization (including having them issue an annual statement in support of individuals with disabilities), coordinating with the local Division of Vocational Rehab, developing an accessible recruiting tool, and developing flexible workplace policies.
For those who were unable to attend the webinar, the OFCCP will be making the presentation and slides available on their website.