On March 24, 2014, the Office of Federal Contract Compliance Programs’ (“OFCCP’s”) final rules for individuals with disabilities under Section 503 of the Rehabilitation Act and for veterans under the Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) went into effect. There are two effective dates under the final rules:

• The requirements that are not specific to affirmative action plans must be implemented by March 24, 2014; and
• The affirmative action plan requirements under Subpart C in the final rules must be in place by the contractor’s next affirmative action plan cycle following March 24, 2014.  This means, if a contractor’s affirmative action plan begins on January 1 every year, the contractor would not have to implement the affirmative action plan requirements until January 1, 2015.

Our previous alert on these new rules explains in detail the requirements flowing from these rules and the timing of those changes.