In FAQs released yesterday, OFCCP addressed requirements under the new Scheduling Letter for contractors to provide updated data collected pursuant to the revised Veterans and Individuals with Disability regulations if the contractor is more than six months into its current AAP plan year upon receipt of a Scheduling Letter.

OFCCP has previously indicated a contractor’s compliance with Subpart C of the new regulations does not go into effect until the contractor first updates its AAP after the March 24, 2014 effective date for the regulations.

Thus, contractors who are not yet subject to Subpart C of the new regulations are not required to provide the six month updates on itemized listing items under VEVRAA or Section 503 until they are more than six months into their plan year after they become subject to Subpart C.