The United States Supreme Court has declined to accept Associated Builders & Contractor’s request to review the legality of OFCCP’s recently enacted regulations for individuals with disability.  This rejection signals the end of ABC’s year and a half long challenge of the Agency’s Section 503 regulations.

While this may be the final chapter for ABC’s challenge, the Agency and employers are still navigating through the initial “transition” year of both the Section 503 and VEVRAA regulations.  Though the regulations went into effect March 24, 2014, contractors have until they next regularly update their AAP to implement compliance with the data collection and some of the other obligations of the regulations.  This “transition” period is where contractors are working towards full implementation and have started collecting, but may not have a full year’s worth of data to report in their AAP.  OFCCP recently offered sample VEVRAA and Section 503 Transition Year AAPs to give contractors an idea of what a compliant transition year AAP might look like.

How the Agency will enforce these regulations going forward is yet to be seen but OFCCP but we will be sure to keep you updated on any enforcement trends or insights as we learn of them.