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ARTICLE · 03 JUNE 2008

Employment Law Commentary, May 2008

Morrison Foerster
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The EEO-related obligations associated with federal government contracting, including the requirement to prepare and implement an Affirmative Action Plan (AAP), can be fairly characterized as byzantine.

United StatesEmployment and HR
Nancy Purvis
Nancy Purvis
Lloyd Aubry, Jr.
Lloyd Aubry, Jr.
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OFCCP Regulations Implementing Jobs for Veterans Act of 2003 Finalized

The EEO-related obligations associated with federal government contracting, including the requirement to prepare and implement an Affirmative Action Plan (AAP), can be fairly characterized as byzantine. The most recent complication facing government contractors is the Office of Federal Contract Compliance Programs' (OFCCP) recent publication of final regulations implementing the Jobs for Veterans Act of 2003 (JVA) at 41 CFR 60-300. Unfortunately, in publishing new regulations for veterans, OFCCP did not rescind the old regulations at 41 CFR 60-250 under the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA). Federal contractors now must determine which law applies and then must comply with the corresponding regulations. The purpose of this article is to provide a roadmap for that process.

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