503 AND VEVRAA AUDIT ACTIVITY: NEW REGULATIONS OVERSHADOWING CURRENT REGULATIONS?
Below is a sample of recent data requests that DCI has been privy to:
- The number of applicants that self-identified as a veteran or person with a disability
- A list of applicants referred, during the review period, who were identified as a qualified veteran, and/or individual with disabilities
- Documentation of formal briefing sessions, preferably on company premises, with representatives from recruiting sources including,
- Formal arrangements for referral of applicants;
- Follow up with recruitment sources; and
- Feedback on disposition of applications.
- The number of individuals with disabilities hired
- The number of veterans hired
- A list of employees who have self-identified as individuals with disabilities
If presented with one of the above requests in a compliance review, how should you respond to the compliance officer? We suggest not denying access to information your organization has collected based on the current regulations (e.g., number of individuals with disabilities hired – – – obtained via voluntary self-identification post offer). However, if there are requests that go beyond what is required by the current regulations (e.g., list of applicants that self-identified as individuals with disabilities), we recommend addressing any concerns directly with the assigned compliance officer. If not resolved by the compliance officer, then it is appropriate to escalate up the chain of command to their superior, and ultimately the National office if it cannot be resolved locally.
by Yevonessa Hall, M.P.S, Associate Consultant and Keli Wilson, M.A., Senior Consultant, DCI Consulting Group