CSAVR 2014 – Updates on Section 503 and the ADA Crosswalk

Report
CSAVR Spring 2014
CSAVR
1
April 2014
UPDATES ON SECTION 503
AND THE ADA CROSSWALK
BUSINESS PANEL
CSAVR
Collver, Director,
Enterprise/HR Compliance,
Raytheon, NILG
 Jeanne Goldberg, Senior Attorney
Advisor, Office of Legal Counsel,
EEOC
 Naomi Levin, Branch Chief for
Policy, OFCCP
 Kathy West-Evans, Director of
Business Relationship, CSAVR
April 2014
 Cynthia
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THE FUTURE OF DISABILITY EMPLOYMENT
National Governor’s Association: A Better
Bottom Line
 Executive Order 13548: Federal Agencies
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CSAVR
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April 2014
 The
203,694 in FY 2011 to 219,975 in FY 2012
Increase from 10.97 to 11.89 percent
New hires who were people with disabilities totaled
16,653, representing an increase from 14.65 percent
in FY 2011 to 16.31 percent in FY 2012
Highest representation in 32 years
 Section

503 and VEVRRA: Federal Contractors
Effective March 24, 2014
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SECTION 503
April 2014
 Section
503 - The Rehabilitation Act of
CSAVR
1973
 Section 503 prohibits employment
discrimination on the basis of disability by
Federal government contractors and
subcontractors. Section 503 also requires
that covered contractors take affirmative
action to employ and advance in
employment qualified individuals with
disabilities.
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VEVRAA
CSAVR
Vietnam Era Veterans’
Readjustment Assistance Act of 1974
(VEVRAA), prohibits employment
discrimination against protected
veterans by covered Federal
contractors and subcontractors, and
requires that they take affirmative
action to employ and advance in
employment these veterans.
April 2014
 The
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WHY THE CHANGE?
April 2014
No changes or updates since the 1970’s
 Revised the definition of "disability" and made
changes to comply with the ADA and the
Amendments Act of 2008.
 Veterans face substantial obstacles in finding
employment in the civilian workforce
 The unemployment rate of people with disabilities
continues to be significantly higher than nondisabled
 Increase contractor accountability for compliance and
ultimately increase employment opportunities
 Increased focus on an affirmative action approach

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DEFINING FEDERAL CONTRACTORS
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CSAVR
and Sub-contractors
$10,000 or more in Federal funds
requires non-discrimination
$50,000 and 50 or more employees
requires both non-discrimination and
an Affirmative Action Plan
April 2014
Contractors
 Pre-offer:
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invitation to self-identify as an
individual with a disability (IWD)*
 Post-offer: invitation to self-identify as
an individual with a disability.
 Employees: invitation to all employees in
first year; and every five years thereafter
 All invitations - use the form posted on
OFCCP web site. Very specific language
April 2014
KEY PROVISIONS 503:
VOLUNTARY SELF-IDENTIFICATION
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KEY PROVISIONS: UTILIZATION GOAL
April 2014
Not a quota
 503 - establishes a nationwide 7% utilization goal.
 VEVRAA – establishes an 8% utilization goal for
Veterans
 If a company with 100 or fewer employees applies
to the entire workforce
 If more than 100 employees, the utilization goal
applies to each job group annually
 If goal not met, determine if impediments to EEO
exist; take steps to correct any identified
problems
 Failure to meet goal is NOT a violation
 Phased in compliance

CSAVR
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AFFIRMATIVE ACTION PLANS (AAP)
April 2014
CSAVR
Effective March 24, 2014
 AAP cycle of the contractor
 Requires outreach and recruitment – includes
examples such as VR, VA-VR&E, EN, EARN
 Requires documentation of activities and annual
written assessment of the effectiveness of each of
its activities.
 If totality of efforts not effective, must identify
and implement alternative efforts.
 Must retain these records for 3 years.

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AAP – DATA COLLECTION
AND ANALYSIS
CSAVR
contractors to document and
update the following data points annually:
 Number of protected veteran/IWD
applicants;
 Total number of applicants for all jobs;
 Total number of job openings and jobs
filled;
 Number of protected veteran/IWDs hired;
and
 Total number of applicants hired.
 Must maintain these records for 3 years.
April 2014
 Requires
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CSAVR
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National infrastructure
Easily accessible network
Team of qualified staff
Support to “position business as a company of choice”
Building a strategic plan with business
“getting the ship ready to sail”
April 2014
POSITIONING THE NET – VR:
AS A RESOURCE TO BUSINESS
Key players
Policies, procedures and processes
Staff training and education
Access to workplace and online sites
Four tiered approach to talent acquisition and retention
Talent Acquisition Portal ® (TAP) - Providing access to
the largest talent pool of candidates with disabilities.
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TALENT ACQUISITION PORTAL - TAP
CSAVR
April 2014
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April 2014
CSAVR
Are WE
Ready?
The
Time
is Now!
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