In August 2018, OFCCP released Directive 2018-04 announcing the Agency’s implementation of Section 503 Focused Reviews. Long a priority Director Craig Leen, the Agency is hopeful the reviews will improve compliance with the regulations and promulgate EEO for Individuals with Disabilities. OFCCP has indicated it will start scheduling the Section 503 Focused Reviews with the Agency’s upcoming round of CSALs.

When first announced, there were many questions surrounding what information OFCCP would request while conducting a Focused Review. Late in 2018, OFCCP obtained approval for an abbreviated Section 503 Scheduling Letter, confirming the Agency would be requesting a subset of data provided in a traditional review during the focused reviews.

On Friday, OFCCP provided additional insight and guidance with the launch of a new Section 503 Focused Review landing page. In addition to providing a sample of the Focused Review Scheduling Letter, the website also includes a list of employer best practices and resources as well as a set of FAQs.

Here are some of the highlights of the FAQs:

  • At least initially, OFCCP will conduct Section 503 Reviews at a contractor’s corporate headquarters. 
  • OFCCP will not review the contractors Executive Order 11246 AAP during a Section 503 Review; however, submission of the EO 11246 AAP (not including supporting data e.g. Items 18 and 19 of the EO Scheduling letter) is required as part of the initial submission.
  • OFCCP will not schedule contractors for other compliance reviews while undergoing a Section 503 Review.
  • OFCCP will not require submission of personnel data for a Focused Review other than data required by 41 CFR §60 741.44(k). After reviewing data, OFCCP may request applicant flow data for job groups containing applicants with disabilities.
  • Compliance officers may request compensation and promotion data for individuals who identified as having a disability, are known to have a disability, or have requested a reasonable accommodation.

OFCCP has announced that it would release the next round of CSALs in the second half of March. OFCCP will publicly release these CSALs on its website with actual scheduling letters to follow by mail beginning 15 days later.

We’ll continue to monitor and report on the latest developments in the coming weeks so stay tuned.

Tags: CSAL, CSALs, Focused Reviews, OFCCP, Office of Federal Contract Compliance Programs, Scheduling Letter, Section 503 FAQs, Section 503 Focused Reviews, Section 503 of the Rehabilitation Act of 1973
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Photo of Laura A. Mitchell Laura A. Mitchell

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating…

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating legal risk. Laura is a guiding force in the firm’s most specialized and technical practice areas where she leverages an analytics-focused approach to partner with her clients in building legally compliant programs around which they can anchor their workplaces achieving productivity and stability.

Laura understands that creating a competitive advantage for employers in today’s workplace involves using a data-driven approach to counsel companies on the development of proactive and equitable non-discriminatory practices in hiring, promotions, separations and pay—and where advancements in technology can create both opportunities for efficiencies and risk that can be measured. Committed to putting her clients’ organizational goals first and foremost while balancing legal risk, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication. Staying the course with employers across their organizational journey while balancing legal compliance obligations throughout their employees’ lifecycle ensures Laura’s position as a go-to resource.

Laura works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize the combined vision of legal compliance, increased productivity and economic growth enhanced by a focus on pay equity.  As part of the pay equity journey, she advises employers on the evolving pay transparency landscape, working to align compliant practices with the practical realities of the business world.

Laura partners closely with government contractors to understand, implement and demonstrate compliance with their EEO regulatory and compliance obligations. She also works closely with non-government contractor clients to conduct risk assessments of their programs, policies, and training to align with federal and state anti-discrimination requirements.

Laura is the editor and a principal contributor of the GovCon Employment Exchange blog and presents on pay equity and government contractor obligations. To round out her days, Laura enjoys spending time with her family and friends attending sports events, working out, riding her bike, playing pickleball and taking in Colorado’s incomparable sunsets.

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