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Federal contractors are required to maintain all personnel or employment records made by the contractor for a period of two (2) years from the date of the making of the personnel record or the personnel action, whichever occurs later. 

Examples of records that must be maintained include:  job descriptions; job postings and advertisements; records of job offers; applications and resumes; interview notes; tests and test results; written employment policies and procedures; and personnel files. 

Contractors with fewer than 150 employees, or who do not have a government contract of at least $150,000 only need to keep records for one (1) year. 


Vietnam Era Veterans’s Readjustment Assistance Act of 1974, as amended (VEVRAA) – Requires that contractors and subcontractors with a federal contract or subcontract in the amount of $100,000 or more, entered into on or after December 1, 2003, for the purchase, sale, or use of personal property or non-personal services (including construction), take affirmative action to employ and advance in employment qualified covered veterans. 

The category of Vietnam era veterans was eliminated from coverage under VEVRAA.  However, many Vietnam era veterans may remain covered in other catagories.  A new category of covered veterans was added:  Those "veterans who, while serving on active duty in the Armed Forces, participated in a United States military operation for which an Armed Forces service medal was awarded pursuant to Executive Order 12985."  Coverage of veterans with disabilities was expanded to include all veterans with service-connected disabilities.  The coverage of "recently separated veterans" was expanded from one to three years after discharge or release from active duty.


Section 503 of the Rehabilitation Act of 1973, as amended, requires employers with federal contracts or subcontracts that exceed $10,000, and contracts or subcontracts for indefinite quantities (unless the purchaser has reason to believe that the cost in any one year will not exceed $10,000), to take affirmative steps to hire, retain, and promote qualified individuals with disabilities. 

The regulations implementing Section 503 make clear that this obligation to take affirmative steps includes the duty to refrain from discrimination in employment against qualified individuals with disabilities.


  •  www.dol.gov/DOL/allcfr/OASAM/title_29/Part_30/29CFR30.4.htm

  •  www.dol.gov/compliance/laws/comp-vevraa.htm

  •  www.dol.gov/compliance/guide/503.htm

  •  www.dol.gov/esa/regs/compliance/ofccp/pdf/sampleaap.pdf




 

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