The OFCCP Digest Local JobNetwork The OFCCP Digest
The Importance of Disposition Codes: What can we learn from OFCCP v. Bank of America?
Topic: Internet Applicant Rule
In OFCCP audits, the greatest risk of a big dollar, “hidden” discrimination finding has always been and continues to be from applicant to hire adverse impact analyses. Despite all the recent press surrounding the Agency’s heightened focus on finding and eradicating compensation...more
Scott Pechaitis, Esq. Scott Pechaitis, Esq.
Principal at Jackson Lewis P.C.
Chris Patrick, Esq. Chris Patrick, Esq.
Associate at Jackson Lewis P.C.
The 2016 Industry Liaison Group National Conference
Topic: NILG
The 2016 Industry Liaison Group (NILG) national conference was held August 2-5 in Charlotte, North Carolina. The conference included a broad cross-section of presentations featuring speakers from the public and private sectors. While the formal theme of the conference...more
Bill Osterndorf
President and Founder of HR Analytical Services
Mid-Year Review: OFCCP Audits and What to Expect
Topic: OFCCP Audits
With summer coming to an end, activity at the Office of Federal Contract Compliance Programs (OFCCP) seems to still be heating up as the agency begins to wrap up its final full fiscal year of the Obama Administration—which closes September 30...more
Lynn Clements Lynn Clements
Director of Regulatory Affairs at Berkshire Associates Inc.
Interview Accommodations for People with Disabilities
Topic: Individuals with Disabilities
When most employers think about accommodations for people with disabilities, they generally think about the period after hiring. Many persons with disabilities may require accommodations for the interview and application process...more
Sheryl Letwat Sheryl Letwat
Consultant at Clearbrook

Ask the Experts is an online forum where federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity. Simply register your company on to submit a question. Questions and answers will occasionally be featured in The OFCCP Digest for the benefit of all readers.

Question: Reasonable Accommodations

What is the requirement for reasonable accommodations in our EEO tagline? Is our company required to list our phone number?

Answered by Amy Wozniak from

Federal contractors are required to state in all solicitations or advertisements for employees their status as an equal opportunity employer and that all qualified applicants will receive consideration without regard to their status as a member of a protected group. The Office of Federal Contract Compliance Programs (OFCCP) provided a sample tagline that you could use in its E.O. 13672 Frequently Asked Questions that states the following: “Equal Opportunity Employer – minorities/females/veterans/individuals with disabilities/sexual orientation/gender identity.” There is no requirement to include language regarding reasonable accommodations or your phone number within the EEO tagline itself.

However, federal contractors are obligated to include information, somewhere in your job posting, regarding how a person with a disability can request an accommodation to complete the application process if that is needed. Notice of how to obtain reasonable accommodations should be provided by the contractor via its online system, as well as on its paper applications and job announcements. Ideally, such notices should be prominently displayed, and included at the beginning of the online application process. At a minimum, these notices should contain the name of the person to contact, and the process for requesting an accommodation.

Final Rule Revising ADA Title II and Title III Regulations

The Department of Justice published a Final Rule revising Title II and Title III regulations of the Americans with Disabilities Act (ADA). The revised regulations provide guidance to covered entities under Title II (state and local governments) and Title III (public accommodations and commercial facilities) as well as to persons with disabilities to ensure that all individuals with disabilities receive the law’s protections. In addition to clarifying that the term “disability” shall be interpreted and applied broadly, the regulations expand the definition of “major life activities,” and establish rules in determining whether an impairment substantially limits a major life activity. The Final Rule will take effect on October 11, 2016. You can learn more about the new regulations here.

2016 VETS-4212 Reporting is Open

The filing season for the VETS-4212 2016 reporting cycle is now open and the filing deadline is September 30.

2016 EEO-1 Reporting is Open

The filing season for the EEO-1 2016 reporting cycle is now open and the filing deadline is September 30.

Read more DOL Highlights throughout the month for timely updates.
Major League Baseball Players Share the Importance of Inclusion

The Office of Disability Employment Policy (ODEP) and the Professional Baseball Athletic Trainers Society (PBATS) recognize the value of establishing a collaborative relationship to nationally promote the employment of people with disabilities. ODEP and PBATS have partnered to conduct outreach, education, and technical assistance activities that advocate the recruitment, hiring, retention, and advancement of individuals with disabilities, including veterans with disabilities.

Check out these public service announcements by former major league baseball players
(Bo Jackson, Jim Abbott, and Curtis Pride) that highlight the importance of judging people on what they can do – whether on the field, in school, or at work. These important messages will be shared at a variety of ballpark events and activities throughout the country.
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The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics. Previous editions are available for easy reference on The OFCCP Digest Archives page. To subscribe or to provide feedback, email
The opinions expressed in this newsletter are the opinions of the individual author(s) and do not necessarily reflect the opinions of the Local JobNetwork™. The information appearing in this newsletter is meant to provide the reader with a general understanding of topics relating to OFCCP compliance requirements and is not legal advice. If you are seeking legal advice to address OFCCP compliance issues or requirements, you should consult an attorney. The Local JobNetwork™ expressly disclaims all liability with respect to actions taken or not taken based on any or all of the contents of this newsletter.