On December 7, 2019, the United States Department of Labor’s Veterans’ Employment and Training Service (VETS) announced the veteran unemployment rate in November of this year was 3.3 percent. As noted in VETS’ latest numbers release, the non-veteran unemployment rate is slightly higher at 3.4 percent.

The Office of Federal Contract Compliance Programs (OFCCP) requires federal contractors and subcontractors who are required to develop affirmative action programs to evaluate the effectiveness of their veteran outreach and recruitment efforts. Federal contractors and subcontractors do so by comparing the percentage of their employees who identify as protected veterans in each of their establishments to the hiring benchmark set for that establishment.

Federal contractors and subcontractors can choose to utilize OFCCP’s Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) national hiring benchmark or adopt their own, using the multi-factor method outlined on OFCCP’s website. Earlier this year, OFCCP announced the VEVRAA national hiring benchmark would be lowered to 5.9 percent.

It is no secret that the historically low unemployment rates cause employers to struggle to find qualified applicants for openings. Federal contractors and subcontractors may be finding it especially difficult to find qualified candidates who identify as protected veterans because the veteran unemployment rate is lower than the non-veteran unemployment rate.

However, federal contractors and subcontractors that have found themselves on the November 2, 2019 Corporate Scheduling Announcement List (CSAL) Supplement with an impending VEVRAA Focused Review should be wary of using this argument with OFCCP. While the disparity between OFCCP’s national hiring benchmark for veterans and the veteran unemployment rate may be vast, compliance officers will still inquire about proactive hiring and recruitment processes. As OFCCP’s VEVRAA Focused Reviews FAQ states, such proactive recruitment and hiring practices should include at least some of the following:

• Enlisting the assistance and support of the following persons and organizations in recruiting, and developing on-the-job opportunities for veterans: from the local Veterans’ Employment Representative in the local employment service office; the local Department of Veterans Affairs Regional Office; the Department of Defense Transition Assistance Program; and local veterans’ counselors and coordinators on college campuses;
• Special efforts to reach students who are disabled veterans;
• Taking any other positive steps necessary to attract qualified protected veterans through state vocational rehabilitation agencies and employment networks;
• Considering veteran applicants who are known to have disabilities for all available positions for which they may be qualified when the position applied for is unavailable;
• Listing job openings with the National Resource Directory’s Veterans Job Bank.

Federal contractors and subcontractors on the VEVRAA Focused Review CSAL should review OFCCP’s VEVRAA Focused Reviews page, which includes numerous resources including best practices and FAQs.

For more information about OFCCP’s CSAL Supplement with VEVRAA Focused Reviews, see our past post and stay tuned for more updates.