In OFCCP’s recent announcement that it will be releasing a list of organizations that will be undergoing affirmative action compliance reviews, the agency also announced that it will be conducting “focused reviews” during 2019. OFCCP first announced that it would be conducting focused reviews in Directive 2018-04, released in August of 2018. The agency intends to conduct 500 compliance reviews focused on the affirmative action law regarding individuals with disabilities.

In preparation for conducting its focused reviews, OFCCP has prepared a revised version of the letter used to open an affirmative action compliance review. (This letter is referred to as a “scheduling letter.”) The revised scheduling letter includes only items relating to the requirements associated with Section 503 of the Rehabilitation Act, the law that requires affirmative action for individuals with disabilities. The revised scheduling letter can be found on the Office of Management and Budget’s website at https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=201811-1250-001.

Federal contractors and subcontractors that are scheduled to undergo a focused review should be ready to provide information on the following:

• Specific outreach efforts made to recruit individuals with disabilities
• Data regarding applicants, hires, and promotions for individuals with disabilities
• Efforts made to review employment policies and practices for their impact on individuals with disabilities
• Reasonable accommodation requests made by applicants and employees and actions taken to provide reasonable accommodation