CWC has submitted comments to the Office of Federal Contract Compliance Programs (OFCCP) supporting the agency’s plan to renew the recordkeeping and reporting requirements arising under regulations implementing Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).
The proposal would keep VEVRAA’s longstanding recordkeeping, reporting, and enforcement requirements. This includes, for example, the contents of the written affirmative action program, annual assessment of outreach, data collection and metrics, and regular communications to state agencies, union officials, subcontractors, and other key stakeholders.
CWC’s comments support OFCCP’s proposed renewal and recommend that the agency consider clarifying guidance related to assessing the effectiveness of external veteran outreach efforts. The comments further urge OFCCP to consider issuing new guidance stating that contractors are permitted to define relevant terms in a manner consistent with other federal, state, and local requirements.