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Today is the day these new regulations are effective! However, contractors will not be expected to do it all or have it all done on this day. Many of the new requirements are contained in the section of the regulations that the OFCCP has allowed employers to wait until their current AAPs expire.

Here is a copy of the compliance checklist that we sent out earlier. The items that you need to do now are:

B. Outreach/Linkages

D. Internal Dissemination

I. Include EO Clauses in Contracts and Subcontracts

J. Recordkeeping

Some of the above items you are already currently doing; others may need to have the wording revised slightly. Regarding the remainder of the items listed on the checklist, we will incorporate those at the time your AAP is updated. In the meantime, if you have any questions, or would like to schedule a meeting sometime to discuss the new regulations, please let us know.

One additional note regarding self-identification. If you chose not to use the new pre-offer self-identification forms for veterans and individuals with disabilities until your current plan expires, please be sure you are asking veterans and individuals with disabilities to identify post offer (i.e. have them complete the forms along with other pre-hire paperwork).

Also, the OFCCP has developed a new database to help contractors find and recruit qualified veterans and individuals with disabilities.

I tried working with this website several times and it did not turn up anything. If there are still bugs in it, perhaps the OFCCP will work through them, but I wanted to pass along the information to you anyway. Maybe you will have better luck!

As always, please let us know if you have any questions or concerns.