OFCCP released its latest FAQ, this one offering details on VEVRAA Focused Reviews. There appears to be many similarities between the information for VEVRAA Focused Reviews and the Section 503 version.
With the new scheduling letters approved, this guidance is a valuable resource for companies preparing for OFCCP’s next steps. Federal contractors on the November 2019 CSAL list would be wise to use these details to plan for their reviews, especially.
A valuable piece in the VEVRAA FAQ notes that “All VEVRAA focused reviews on the supplemental scheduling list issued in November 2019 will include an on-site review.” It was previously believed that some establishments would not receive an on-site review based on their response to the scheduling letter. This squashes that idea for the time being.
There is also one key difference laid out in the VEVRAA Focused Reviews FAQ versus the Section 503 information. OFCCP states that “VEVRAA focused reviews will take place at contractors’ corporate headquarters and/or establishment locations.” This indicates that OFCCP may visit a company’s headquarters and other establishments within the same round of reviews.
Conversely, the Section 503 Focused Reviews begin at the corporate headquarters, then OFCCP evaluates if it should visit establishments in a second round of reviews. In this case, it would be (presumably) if any potential issues are found at the headquarters.
It is likely that VEVRAA Focused Review scheduling letters will be received shortly (if not already). And as we approach the middle of 2020, all federal contractors should examine the OFCCP Compliance VEVRAA Audit Checklist to ensure they are prepared. Meanwhile, if you are looking for more information on VEVRAA outreach and requirements, you can check out OFCCP’s best practices page and watch this free webinar.