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Focused Review Frequently Asked Questions

  1. What is a Section 503 focused review?
  2. Why is OFCCP conducting Section 503 focused reviews?
  3. Where can I learn more about the Section 503 Focused Review?
  4. The Section 503 focused review scheduling letter requests our Executive Order 11246 AAP as well. Will OFCCP review the Executive Order (EO) AAP during a 503 focused review?
  5. If a contractor is in the middle of a Section 503 focused review, can it also be scheduled for other types of reviews?
  6. Upon being scheduled for a Section 503 focused review who do I need to talk to or email for Compliance Assistance, Outreach and Education?
  7. How can I contact OFCCP if I have questions about the Section 503 Focused Review Compliance Evaluation?
  8. Does the Section 503 Focused Review Scheduling Letter request data and information required in the Section 503 regulations?
  9. Will OFCCP analyze personnel activity data during a Section 503 focused review?
  10. Will focused reviews take place at all contractor facilities?
  11. What will OFCCP examine and assess during a Section 503 focused review?
  12. Has OFCCP identified any Section 503 best practices to assist organizations and employers with recruitment, hiring, and retention of individuals with disabilities?

 


 

1. What is a Section 503 focused review?

On August 10, 2018, OFCCP issued Directive 2018‐04, Focused Reviews of Contractor Compliance with Executive Order 11246, Section 503, and VEVRAA, that directs a portion of future scheduling lists to include focused reviews.

A focused review is one that is restricted to one or more components of the contractor’s organization or one or more aspects of the contractor’s employment practices. Section 503 focused reviews will include a comprehensive review of the contractor policies and procedures as they relate solely to Section 503. The reviews will also include an onsite investigation and interviews with managers responsible for equal employment opportunity and Section 503 compliance (such as the ADA coordinator) as well as employees affected by those policies. OFCCP would also seek to evaluate the handling of accommodation requests, to ensure that individuals with disabilities are not being discriminated against in employment.

 


 

2. Why is OFCCP conducting Section 503 focused reviews?

OFCCP and the Department of Labor are committed to protecting the rights of individuals with disabilities in the workplace and eliminating barriers to equal employment opportunities for these individuals. The labor force participation rate for individuals with disabilities is comparatively low (about 20%) and the unemployment rate is comparatively high (about 8%). As a demonstration of our commitment, OFCCP will conduct focused reviews under Section 503 to ensure that federal contractors fully comply with equal employment opportunity obligations and consider additional best practices to increase employment of qualified individuals with disabilities. Ensuring these steps are taken can help to reduce the rate of unemployment among individuals with disabilities, which is two times the rate of employment for non‐disabled individuals, and shift workplace culture to promote a culture of inclusiveness.

 


 

3. Where can I learn more about the Section 503 Focused Review?

OFCCP created a landing page that specifically discusses Section 503 focused reviews. These materials can be accessed at: https://www.dol.gov/ofccp/Section503-FocusedReviews/index.html

 


 

4. The Section 503 focused review scheduling letter requests our Executive Order 11246 AAP as well. Will OFCCP review the Executive Order (EO) AAP during a 503 focused review?

No. OFCCP will not conduct a review of the Executive Order Affirmative Action Program (AAP) during a Section 503 focused review. While OFCCP will request the EO AAP as part of the Section 503 focused review, the EO AAP will only be used to help the OFCCP compliance officer get a clearer picture of the contractor’s organizational structure, confirm Section 503 job groups, and understand generally how the Section 503 compliance strategies fit with the contractor’s other affirmative efforts. OFCCP will not analyze data contained in the EO AAP to look for discrimination based on sex or race and ethnicity. If elements of the EO AAP document are missing or insufficient on their face, OFCCP will note those issues and take appropriate actions, beginning with technical assistance, to bring the contractor into compliance. For example, if the EO AAP job group analysis does not include a list of the job titles that comprise each job group, OFCCP will provide technical assistance and require the contractor to submit the missing information, which will then be noted in the closure notice.

 


 

5. If a contractor is in the middle of a Section 503 focused review, can it also be scheduled for other types of reviews?

No. While a focused review is pending at a given establishment, that establishment will be exempt from the scheduling of additional compliance evaluations. However, if OFCCP receives a complaint during the course of a focused review alleging violations under any of the three laws OFCCP administers, OFCCP will investigate the complaint accordingly.

 


 

6. Upon being scheduled for a Section 503 focused review who do I need to talk to or email for Compliance Assistance, Outreach and Education?

Contractors are encouraged to take advantage of OFCCP’s technical assistance materials which can be found on OFCCP’s website at https://www.dol.gov/ofccp/ under the "Federal Contractor Corner" section. The contractor can also contact the OFCCP regional and/or district office that sent the scheduling letter for any other questions about the compliance evaluation process or if they require individualized compliance assistance. OFCCP’s District Office staff will contact the contractor to offer technical assistance prior to or immediately after sending the scheduling letter.

 


 

7. How can I contact OFCCP if I have questions about the Section 503 Focused Review Compliance Evaluation?

To get additional information about Section 503 focused reviews, contractors may contact the OFCCP Help Line at 1‐800‐397‐6251 (TTY 1‐877‐889‐5627).

 


 

8. Does the Section 503 Focused Review Scheduling Letter request data and information required in the Section 503 regulations?

Yes. The Section 503 Focused Review Scheduling Letter and Itemized Listing specify the documents and data related to Section 503 that a contractor must provide to OFCCP when selected for a 503 focused review. These items include the contractor’s Section 503 AAP, and the documentation and information required by Subpart C of the regulations, including but not limited to the contractor’s utilization analysis of the representation of individuals with disabilities, evaluation of outreach and recruitment efforts, and the data described in 60‐741.44(k).

 


 

9. Will OFCCP analyze personnel activity data during a Section 503 focused review?

OFCCP will not require the submission of personnel activity data other than the data described in 60‐741.44(k) at the onset of a Section 503 focused review. However, during the course of the review, OFCCP may request and review this information. OFCCP may request compensation and promotion data for individuals who identified as having a disability, are known to have a disability, and/or employees who requested a reasonable accommodation. Additionally, based on a review of data in response to 60‐741.44(k), OFCCP may request additional applicant flow data for job groups that had applicants with disabilities.

 


 

10. Will focused reviews take place at all contractor facilities?

The first round of Section 503 focused reviews will take place at contractors’ corporate headquarters locations. OFCCP will evaluate whether it wishes to schedule other establishments for focused reviews in the future.

 


 

11. What will OFCCP examine and assess during a Section 503 focused review?

During a Section 503 focused review, OFCCP will assess the contractor’s compliance with all elements of the Section 503 regulations, including whether the contractor conducted the required assessments of its employment policies and tracked appropriate data concerning individuals with disabilities.

OFCCP will also provide compliance assistance identifying ways in which contractors can go above and beyond the minimum requirements by implementing best practices intended to increase the utilization of qualified individuals with disabilities within their workforce. During a review, OFCCP will collect information about any measures the contractor has taken beyond those required in the regulations. For those contractors that demonstrate innovative and successful diversity and inclusion efforts for individuals with disabilities, OFCCP will examine ways to recognize the contractor for its efforts, consistent with OFCCP’s Directive 2018‐06: Contractor Recognition Program.

 


 

12. Has OFCCP identified any Section 503 best practices to assist organizations and employers with recruitment, hiring, and retention of individuals with disabilities?

Yes, OFCCP has identified best practices to assist organizations and employers. Best practices are located on OFCCP’s Section 503 Focused Review landing page.