Here are some government sources to help you determine whether or not you are a contractor: If you hold government bills of lading, serve as a custodian of federal funds, or are an issuer and payer of U.S. bonds and savings notes, you must comply with the requirements and laws of the OFCCP. Building relationships with state and local disability and workforce development service providers, such as U.S. vocational rehabilitation agencies, U.S. employment centers, centers for Independent Living (CIL), and other community organizations, can be beneficial for federal contractors who want to proactively recruit people with disabilities and veterans to achieve their goals by under Section 503 and VEVRAA. These service providers can connect federal contractors directly with job seekers with disabilities or provide access to applicants` databases. Because they have a strong local orientation, they can also help identify and train people for specific workforce needs. In the course of doing business with the federal government, federal contractors and subcontractors assume certain obligations. In particular, they are prohibited from discriminating on the basis of sex, race, colour, national origin, religion, disability or protected veteran status.
They are also required to take positive measures (e.g. B proactive measures) to hire people from specific groups who have traditionally been discriminated against. If your company or organization has a federal contract, subcontract or construction contract supported by the federal government, it may be subject to some or all of the civil rights requirements applied by the OFCCP. Generally, any company or organization that (1) holds a single federal contract, subcontract or government-backed construction contract for $10,000.00; (2) has federal contracts or subcontracts totalling more than $10,000.00 over a period of 12 months; or (3) holds government bills of lading, acts as a custodian of federal funds, or is an agent for the issuance and payment of U.S. savings bonds and debentures of any amount that is subject to the requirements of one or more of the laws administered by the OFCCP. Federal contracts or subcontracts, as described above, in an amount greater than $10,000 are subject to Executive Order 11246; those over $15,000 are also subject to section 503 of the Rehabilitation Act, 1973 (section 503); and those over $100,000 are also subject to the Vietnam-Era Veterans Readjustment Assistance Act, 1974, as amended (VEVRAA). However, construction contracts and subcontracts supported by the Confederation are subject only to Executive Order 11246. See: 41 CFR Sec. 60-1.5(a), 41 CFR Sec. 60-300.4 and 41 CFR Sec. 60-741.4. If your construction company or organization has a federal contract, a federal subcontract or a federally supported contract for a period of more than $10,000 for a period of 12 months, you may be subject to the civil rights requirements applied by the OFCCP.
To learn about your federal obligations, visit our interactive page: CLICK HERE It is important to note that affirmative action goes beyond equal employment opportunity and requires targeted outreach to facilitate the recruitment, hiring, retention and promotion of employees from diverse backgrounds. While federal contractors and subcontractors (and federal agencies) are required to take positive action, some employers voluntarily adopt affirmative action plans to create a more balanced workforce. Some general conclusions at this time are that if you are a business operating under an existing federal contract that is not renewed or by which options are exercised, you are not subject to the Order in Council. If your contract is less than $250,000, you are probably not subject to the mandate. However, it seems that this is not limited to local contractors (such as those in the construction industry), and therefore the vaccination mandate could extend to many more companies (such as banks) that operate under a federal contract but do not offer on-site work for federal agencies. It is extremely important to know if you are a federal contractor or not. Trust us, you don`t want to be surprised when the U.S. Department of Labor`s Office of Federal Contract Compliance Programs (OFCCP) sends you an audit letter and asks you to see your AAP.
Of course, all this is very preliminary, given the lack of guidance from the Working Group. But for now, employers can at least have an idea of whether or not they are a contractor for the purposes of the decree. While specific details of the mandate are still pending, companies that have new or renewed federal contracts (over $250,000) can expect some sort of vaccination mandate for at least part of their workforce and should start planning accordingly. .