The OFCCP recently added two new “FAQs” to its website to help explain contractors’ obligations under new Section 503 and VEVRAA regulations. The first addresses the information contractors must maintain related to efforts to invite voluntary self-identification of disability.The FAQ informs contractors that if the contractor uses an electronic version of the required disability self-identification form to solicit disability status, the contractor need only retain the data, not the form or copy of the form, provided that its system does not store completed forms. However, if the contractor only maintains this form of data, it must also be able to demonstrate how it delivered or displayed the invitation to self-identify so that the OFCCP can verify that the contractor used the OMB-approved form. If the contractor used paper invitations to invite self-identification of disability, it must retain either hard copies of the forms or electronic copies of the forms (such as scanned pdf files).Contractors utilizing paper forms must also retain any data compilation prepared that records the information from the paper self-identification forms.
The second new FAQ informs contractors that where they have openings for a remote position, that opening should be listed with the state workforce agency “where the work unit, division, department or supervisor to which the employee will report or be assigned is located.”