An AAP, to be acceptable, must affirm that the contractor reviews its personnel processes periodically. These processes must provide for the careful, thorough and systematic consideration of the job qualifications of applicants and employees with known disabilities for job vacancies filled either by hiring or promotion, and for all training opportunities offered or available. A contractor’s AAP must describe the review, include the date the review was performed, and describe actions taken or changes made as a result of the review.46
a. Adequacy of Present Procedures. Contractors may assert that their present personnel procedures are adequate and indicate that modifications to the procedures are unnecessary. COs must determine whether the information received during the desk audit supports that assertion to determine acceptability. COs must request additional information during the desk audit or on-site review if they are unable to make an acceptability determination.
b. Adverse Stereotyping. Part of the contractor’s review must be to ensure that its personnel processes are not stereotyping individuals with disabilities in a manner that limits their access to jobs for which they are qualified.
c. Access to Personnel Processes. The contractor must also ensure that applicants and employees with disabilities have equal access to personnel processes, including those implemented through information and communication technologies. Ensuring equal access to personnel processes includes providing any necessary reasonable accommodation to ensure that qualified applicants and employees with disabilities are able to apply, and are fully considered, for vacancies, promotions, and training opportunities. Appendix A to 41 CFR Part 60-741 provides guidelines for contractors on their duty to provide reasonable accommodations. With respect to the application process, an example of appropriate accommodation could be the provision of information on vacancies in a form accessible to those with vision or hearing impairments who have requested an accommodation. Though Section 503 and its implementing regulations do not require contractors to make their information and communication technology publicly “accessible,” contractors are encouraged to do so.
46. This information is requested in the Itemized Listing, under 41 CFR 741.44(b).