U PDATES ON S ECTION 503 AND THE ADA C ROSSWALK CSAVR Spring 2014 April 2014 CSAVR 1

B USINESS P ANEL Cynthia Collver, Director, Enterprise/HR Compliance, Raytheon, NILG Jeanne Goldberg, Senior Attorney Advisor, Office of Legal Counsel, EEOC Naomi Levin, Branch Chief for Policy, OFCCP Kathy West-Evans, Director of Business Relationship, CSAVR April CSAVR

T HE F UTURE OF D ISABILITY E MPLOYMENT The National Governor’s Association: A Better Bottom Line Executive Order 13548: Federal Agencies 203,694 in FY 2011 to 219,975 in FY 2012 Increase from to percent New hires who were people with disabilities totaled 16,653, representing an increase from percent in FY 2011 to percent in FY 2012 Highest representation in 32 years Section 503 and VEVRRA: Federal Contractors Effective March 24, 2014 April CSAVR

S ECTION 503 Section The Rehabilitation Act of 1973 Section 503 prohibits employment discrimination on the basis of disability by Federal government contractors and subcontractors. Section 503 also requires that covered contractors take affirmative action to employ and advance in employment qualified individuals with disabilities. April CSAVR

VEVRAA The Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA), prohibits employment discrimination against protected veterans by covered Federal contractors and subcontractors, and requires that they take affirmative action to employ and advance in employment these veterans. April CSAVR

W HY THE C HANGE ? No changes or updates since the 1970’s Revised the definition of "disability" and made changes to comply with the ADA and the Amendments Act of Veterans face substantial obstacles in finding employment in the civilian workforce The unemployment rate of people with disabilities continues to be significantly higher than non- disabled Increase contractor accountability for compliance and ultimately increase employment opportunities Increased focus on an affirmative action approach April CSAVR

D EFINING F EDERAL C ONTRACTORS Contractors and Sub-contractors $10,000 or more in Federal funds requires non-discrimination $50,000 and 50 or more employees requires both non-discrimination and an Affirmative Action Plan April CSAVR

K EY P ROVISIONS 503: V OLUNTARY S ELF -I DENTIFICATION Pre-offer: invitation to self-identify as an individual with a disability (IWD)* Post-offer: invitation to self-identify as an individual with a disability. Employees: invitation to all employees in first year; and every five years thereafter All invitations - use the form posted on OFCCP web site. Very specific language April CSAVR

K EY P ROVISIONS : U TILIZATION G OAL Not a quota establishes a nationwide 7% utilization goal. VEVRAA – establishes an 8% utilization goal for Veterans If a company with 100 or fewer employees applies to the entire workforce If more than 100 employees, the utilization goal applies to each job group annually If goal not met, determine if impediments to EEO exist; take steps to correct any identified problems Failure to meet goal is NOT a violation Phased in compliance April CSAVR

A FFIRMATIVE A CTION P LANS (AAP) Effective March 24, 2014 AAP cycle of the contractor Requires outreach and recruitment – includes examples such as VR, VA-VR&E, EN, EARN Requires documentation of activities and annual written assessment of the effectiveness of each of its activities. If totality of efforts not effective, must identify and implement alternative efforts. Must retain these records for 3 years. April CSAVR

AAP – D ATA C OLLECTION AND A NALYSIS Requires contractors to document and update the following data points annually: Number of protected veteran/IWD applicants; Total number of applicants for all jobs; Total number of job openings and jobs filled; Number of protected veteran/IWDs hired; and Total number of applicants hired. Must maintain these records for 3 years. April CSAVR

P OSITIONING T HE NET – VR: A S A R ESOURCE TO B USINESS National infrastructure Easily accessible network Team of qualified staff Support to “position business as a company of choice” Building a strategic plan with business “getting the ship ready to sail” Key players Policies, procedures and processes Staff training and education Access to workplace and online sites Four tiered approach to talent acquisition and retention Talent Acquisition Portal ® (TAP) - Providing access to the largest talent pool of candidates with disabilities. April CSAVR

T ALENT A CQUISITION P ORTAL - TAP April 2014 CSAVR 13

14 Are WE Ready? The Time is Now! April 2014 CSAVR