August 10, 2010

DOL CONTRACTS WITH FIRM TO ASSESS EXISTING AFFIRMATIVE ACTION POLICIES FOR PEOPLE WITH DISABILITIES AND DISABLED VETERANS

by David Morgan, Consultant, DCI Consulting Group

The US Department of Labor’s Office of Disability Employment Policy (ODEP) has made available two reports on affirmative action, applicable to individuals with disabilities and disabled veterans, in the federal contractor sector.

The agency states on its website that “as part of its mission, ODEP contracted with Economic Systems Inc. to assess existing affirmative action policies applicable to people with disabilities and disabled veterans. Specifically, the policies set out in the regulations implementing Section 503 of the Rehabilitation Act (Section 503) and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) were evaluated to determine whether and how Federal contractor affirmative action programs might be modernized as part of a comprehensive strategy to reduce barriers to employment and eliminate earnings gaps.”

The reports are categorized into two volumes. Volume I discusses data sources and models in terms of extending quantitative analyses and placement goal methodologies, to cover individuals with disabilities. Volume II discusses and provides recommendations for modernizing affirmative action provisions. Some general conclusions and recommendations within the reports, geared toward strengthening and modernizing the affirmative action provisions of Section 503 regulations, include:

  • Developing a specific affirmative action policy to provide qualified individuals with disabilities meaningful employment opportunity, at all levels of employment
  • Developing a specific policy prescribing the purpose of affirmative action programs— management tools designed to ensure equal employment opportunity programs, which include quantitative analyses and placement goals; a system of specific, immediate, realizable, and action-oriented steps; and accountability mechanisms that allow for continuous improvement
  • Modifying the invitation to self-identify at the pre-offer of employment stage to increase employment opportunities for people with disabilities
  • Implementing regulations that include a separate component for outreach and recruitment (i.e., distinguishing external dissemination, from outreach and recruitment)
  • Adding a new component for accessible and usable electronic and information technology

Report Volumes I and II, as well as an Executive Summary of the research firm’s findings and conclusions, can be found on the firm’s website, under Areas of Expertise/Affirmative Action. Those who plan on submitting comments regarding OFCCP’s Advanced Notice of Proposed Rulemaking (ANPRM) on Updating AAP Requirements for People with Disabilities (published in the Federal Register on July 23, 2010), are encouraged to read the ODEP-funded reports. As mentioned in a previous entry, all public comments must be received by September 21, 2010.

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DCI Consulting is a risk management human resources consulting firm strategically located in Washington, D.C.

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