Government contractors and subcontractors

New rules effective March 24, 2014.  

(Please add a comment sharing where on the web you find useful employment legal information.)

We won't be posting every action governments suggest or require though want to remind you that, regardless of company size, covered contractors and subcontractors:

  • Must achieve or create plan to have 7% disabled staff in each job category (Fact Sheet).
    • If less than 100 employees, then 7% across whole workforce.
    • Failure to reach 7% is not necessarily an issue, but failing to have a plan to do so is.
    • Similarly, there is an 8% target for employing veterans, or use your "own benchmark based on the best available data" (Fact Sheet).
    • The laws and regulations for each require (among other things) non-discrimination, non-retaliation, and accommodation for disabilities.  You are NOT required to create a new affirmative action plan effective March 24.  Complete your annual cycle and then apply the new percentage targets.
  • Collect data on applicants (this is not new) and request employees self-identify their status (this is new; recommend you use the federal form).
  • Mention company is an EEO/disability employer, using (somewhat) prescribed language in job postings.
    • It is no longer permissible to to use D/V to mean disabled and veterans.  All words must be spelled out.
    • It seems you may not have to use the full EEO statement on every posting but it must appear in underlying contracts, annual subcontractor/vendor/supplier notifications, etc.
    • You use the full tagline on every posting and certainly meet the requirements, "We are an equal opportunity employer and all qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, disability status, protected veteran status, or any other characteristic protected by law."
  • Must use "appropriate outreach and positive recruitment activities." No specific activities are required but some must be chosen, undertaken, with actions and results documented.

Additional Resources