Checklist for Compliance with Section 503 of the Rehabilitation Act

Checklist for Compliance with Section 503 of the Rehabilitation Act of 1973,

As Amended

INTRODUCTION

Note: this checklist should not be used as a substitute for contractors reviewing their regulatory

requirements and other guidance provided by the Office of Federal Contract Compliance Programs

(OFCCP), which enforces Section 503. Further, using this checklist does not guarantee or equate to

compliance with the regulations.

Purpose of Section 503:

The Section 503 regulations set forth the standards for compliance with section 503 of the

Rehabilitation Act of 1973, as amended (29 U.S.C. 793), which prohibits discrimination against

individuals with disabilities and requires Government contractors and subcontractors to take

affirmative action to employ and advance in employment qualified individuals with disabilities.

[60.741.1]

Definition of Disability from Section 503:

The term disability means, with respect to an individual:

(i) A physical or mental impairment that substantially limits one or more major life

activities of such individual;

(ii) A record of such an impairment; or

(iii) Being regarded as having such an impairment.

General purpose of Section 503’s Subpart C, Affirmative Action Program:

An affirmative action program is a management tool designed to ensure equal employment

opportunity and foster employment opportunities for individuals with disabilities. An affirmative

action program institutionalizes the contractor's commitment to equality in every aspect of

employment and is more than a paperwork exercise. An affirmative action program is dynamic

in nature and includes measurable objectives, quantitative analyses, and internal auditing and

reporting systems that measure the contractor's progress toward achieving equal employment

opportunity for individuals with disabilities.

Applicability of Section 503 Regulation in General and Subpart C, Affirmative Action Program

Requirements in Particular:

The Section 503 regulations apply to all government contracts and subcontracts in excess of

$15,000 for the purchase, sale or use of personal property or nonpersonal services (including

construction, but not federally assisted construction). [60-741.1(b)]

The requirements of Subpart C of the Section 503 rule pertaining to written affirmative action

program requirements apply to every government contractor that has 50 or more employees

and a federal contract of $50,000 or more. [60-741.40(b)]

Checklist for Compliance with Section 503 Subpart C, Affirmative Action Program:

The following Section 503 Subpart C, Affirmative Action Program Checklist is organized to assist

federal contractors with 50 or more employees and a contract of $50,000 or more to benchmark

their current activities against Section 503, Subpart C Affirmative Action Program requirements.

By comparing their current activities against the regulatory requirements, federal contractors

can develop an Affirmative Action Program that ensures equal employment opportunity and

fosters employment opportunities for individuals with disabilities.

The checklist is organized by the Subpart C, Affirmative Action Program section numbers. The

questions are derived from the associated regulatory language. Please note, this checklist

should not be used as a substitute for contractors reviewing their regulatory requirements and

other guidance provided by the Office of Federal Contract Compliance Programs (OFCCP), which

enforces Section 503. Further, using this checklist does not guarantee or equate to compliance

with the regulations.

Checklist for Compliance with Section 503 of the Rehabilitation Act of

1973, As Amended

Subpart C, Affirmative Action Program

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.40(b)

Applicability of

the affirmative

action program.

A. Is your organization developing and maintaining an affirmative

action program at each establishment within 120 days of the

commencement of a federal contract?

B. Does your affirmative action program set forth your policies and

procedures in accordance with Section

503, Subpart C?

C. Is your affirmative action program for Section 503, integrated into

(not required) other affirmative action programs?

A. ___YES ___NO

B. ___YES ___NO

C. ___YES ___NO

§ 60-

741.40(b)

Applicability of

the affirmative

action program.

A. Does your organization's designated official review and update the

affirmative action program on an annual basis?

A. ___YES ,

date of next

review____

B. ___NO

§ 60-741.41

Availability of

affirmative

action program.

A. Does your organization make your affirmative action program

(absent data metrics) available to employees or applicants for

inspection upon request?

B. Does your organization post at each establishment the location and

hours during which the program may be obtained?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.42(a)

Invitation to

Self-Identify:

Pre-Offer.

A. Does your organization invite each applicant at the pre-offer stage

(i.e., when the applicant applies or is considered for employment) to

voluntarily self-identify as an individual with a disability?

B. If the invitation to self-identify is included with the application

materials, is it separate from the application?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.42(a)

Invitation to

Self-Identify:

Pre-Offer.

A. Does your organization invite each applicant at the pre-offer stage

to voluntarily self-identify as an individual with a disability using the

OMB-approved form posted on the OFCCP website?

http://www.dol.gov/ofccp/regs/compliance/sec503/Voluntary_Self-

Identification_of_Disability_CC-305_SD_Edit1.24.14.pdf

A. ___YES ___NO

§ 60-

741.42(b)

Invitation to

Self-Identify

Post-Offer.

A. Does your organization invite each applicant at the post-offer stage

(i.e., after an offer has been made but before the applicant begins his

or her duties) to voluntarily self-identify as an individual with a

disability?

A. ___YES ___NO

§ 60-

741.42(b)

Invitation to

Self-Identify

Post-Offer

A. Does your organization invite each applicant at the post-offer stage

to voluntarily self-identify as an individual with a disability using the

OMB-approved form posted on the OFCCP website?

http://www.dol.gov/ofccp/regs/compliance/sec503/Voluntary_Self-

Identification_of_Disability_CC-305_SD_Edit1.24.14.pdf

A. ___YES ___NO

§ 60-

741.42(c)

Invitation to

Self-Identify:

Employees.

A. Does your organization invite each of your employees to voluntarily

inform you that he or she is an individual with a disability as defined in

§ 60-741.2(g)(1)(i) or (ii)?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.42(c)

Invitation to

Self-Identify:

Employees.

B. Did your organization invite each of your employees to inform you

that he or she is an individual with a disability in the first year your

organization became subject to the 503 regulations and at five year

intervals, thereafter, using the language and manner prescribed by the

OFCCP Director and published on the OFCCP Web site?

http://www.dol.gov/ofccp/regs/compliance/sec503/Voluntary_Self-

Identification_of_Disability_CC-305_SD_Edit1.24.14.pdf

C. Does your organization at least once during the intervening years

between these invitations, remind your employees that they may

voluntarily update their disability status?

B. ___YES ___NO

C. ___YES ___NO

§ 60-

741.42(e)

Invitation to

Self-Identify:

Confidentiality

A. Does your organization keep all of the information on self-

identification confidential and ensure that it is not provided to hiring

officials?

B. Does your organization maintain self-identification records in a

separate data analysis file rather than in the personnel or medical files

of individual employees?

C. Does your organization recognize that it must provide self-

identification information to OFCCP upon request?

D. Does your organization recognize that it may only use the self-

identification information in accordance with the section 503 rule?

A. ___YES ___NO

B. ___YES ___NO

C. ___YES ___NO

D. ___YES ___NO

§ 60-

741.42(g)

Invitation to

Self-Identify:

Liability for

Discrimination

A. Does your organization understand that nothing in this section shall

relieve your organization from liability for discrimination in violation of

section 503?

A. ___YES ___NO

§ 60-741.43

Affirmative

action policy.

A. Does your organization's affirmative action policy include

prohibitions against discrimination because of physical or mental

disability?

B. Does your organization's affirmative action policy include taking

affirmative action to employ and advance in employment qualified

individuals with disabilities at all levels, including the executive level?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(a)

Required

contents of

affirmative

action programs

– Policy

Statement

A. Does your organization have a disability-related equal opportunity

(EO) policy statement included in your affirmative action program?

B. Does your disability-related EO policy statement include language

indicating that your organization will recruit, hire, train, and promote

persons in all job titles and ensure that all other personnel actions are

administered without regard to disability and ensure that all

employment decisions are based only on valid job requirements?

C. Does your disability-related EO policy statement indicate the

support of your organization's top U.S. Executive (e.g., the Chief

Executive Officer or the President of the U.S. Division of a foreign

company) for your affirmative action program?

A. ___YES ___NO

B. ___YES ___NO

C. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(a)

Required

contents of

affirmative

action programs

– Policy

Statement

D. Does your disability related EO policy statement provide for an

audit and reporting system?

E. Does your disability related EO policy statement assign overall

responsibility to one of your organization’s officials for the

implementation of affirmative action activities and does this official’s

identity appear on all internal and external communications regarding

the company’s affirmative action program?

F. Is the disability related EO policy statement posted on company

bulletin boards?

G. As needed, are applicants and employees with disabilities provided

the notice in a form that is accessible and understandable to the

individual with a disability, e.g., Braille, large print, or posting the

notice at a lower height for a person using a wheelchair?

D. ___YES ___NO

E. ___YES ___NO

F. ___YES ___NO

G. ___YES ___NO

§ 60-

741.44(a)

Policy

Statement

A. Does your disability-related EO policy statement state that

employees and applicants shall not be subjected to harassment,

intimidation, threats, coercion, or discrimination because they

engaged in filing a complaint?

A. ___YES ___NO

§ 60-

741.44(a)

Policy

Statement

A. Does your disability-related EO policy statement state that

employees and applicants shall not be subjected to harassment,

intimidation, threats, coercion, or discrimination because they

engaged in assisting or participating in an investigation, compliance

evaluation or other activity related to the administration of section

503 or any other Federal, State, or local law requiring equal

opportunity for individual with disabilities?

A. ___YES ___NO

§ 60-

741.44(a)

Policy

Statement

A. Does your disability-related EO policy statement state that

employees and applicants shall not be subjected to harassment,

intimidation, threats, coercion, or discrimination because they

engaged in opposing any act or practice made unlawful by section 503

or its implementing regulations in this part, or any other Federal, State

or local law requiring equal opportunity for individuals with disabilities

A. ___YES ___NO

§ 60-

741.44(a)

Policy

Statement

A. Does your disability-related EO policy statement state that

employees and applicants shall not be subjected to harassment,

intimidation, threats, coercion, or discrimination because they

engaged in exercising any other right protected by section 503 or its

implementing regulations?

A. ___YES ___NO

§ 60-741.44

(b)

Review of

personnel

processes.

A. Does your organization ensure that its personnel processes provide

for careful, thorough, and systematic consideration of the job

qualifications of applicants and employees with known disabilities for

job vacancies filled either by hiring or promotion, and for all training

opportunities offered or available?

B. Does your organization ensure that its personnel processes do not

stereotype individuals with disabilities in a manner which limits their

access to all jobs for which they are qualified?

A. ___YES ___NO

B. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-741.44

(b)

Review of

personnel

processes.

C. Does your organization ensure that applicants and employees with

disabilities have equal access to your personnel processes, including

those implemented through information and communication

technologies?

D. Does your organization provide reasonable accommodation to

ensure applicants and employees with disabilities receive equal

opportunity in the operation of personnel processes?

E. Does your organization make your information and communication

technologies generally accessible, even absent a specific request for

reasonable accommodation? [Encouraged but not required by the

section 503 rule]

F. Does your organization recognize that it may still have to provide a

reasonable accommodation to an applicant or employee even if your

information and communications technologies meet general

accessibility standards?

G. Does your organization periodically review such processes and

make any necessary modifications to ensure that these obligations are

carried out?

H. Does your organization include in in its affirmative action program a

description of its review and any necessary modifications to personnel

processes or development of new processes required under the

regulations?

I. Does your organization have procedures that facilitate a review of

the implementation of this requirement by your organization?

C. ___YES ___NO

D. ___YES ___NO

E. ___YES ___NO

F. ___YES ___NO

G. ___YES ___NO

H. ___YES ___NO

I. ___YES __NO

§ 60-

741.44(c)

Physical and

mental

qualifications.

A. Does your organization have in its affirmative action program, and

do you adhere to, a schedule for the review of all physical and mental

job qualification standards to ensure that, to the extent qualification

standards tend to screen out qualified individuals with disabilities,

they are job-related for the position in question and are consistent

with business necessity?

A. ___YES ___NO

§ 60-

741.44(c)

Physical and

mental

qualifications.

A. Does your organization ensure that the physical or mental

qualification standards it uses (whether for hiring, promotion, training,

or other change in employment status), to the extent they tend to

screen out qualified individuals with disabilities, are consistent with

business necessity and related to the specific job or jobs?

B. Does your organization understand that if a qualification standard

screens out, or tends to screen out, qualified individuals with

disabilities it has the burden to demonstrate that the standard is job –

related and consistent with business necessity?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(d)

Reasonable

accommodation

to physical and

mental

limitations.

A. As a matter of nondiscrimination, does your organization make

reasonable accommodation to the known physical or mental

limitations of an otherwise qualified individual with a disability unless

you can demonstrate that the accommodation would impose an

undue hardship on the operation of your business?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(d)

Reasonable

accommodation

to physical and

mental

limitations.

B. As a matter of affirmative action, if an employee with a known

disability is having significant difficulty performing his or her job and it

is reasonable to conclude that the performance problem may be

related to the known disability, does your organization confidentially

notify the employee of the performance problem and inquire whether

the problem is related to the employee's disability?

C. If the employee responds affirmatively, does your organization

confidentially inquire whether the employee is in need of a reasonable

accommodation?

B. ___YES ___NO

C. ___YES ___NO

§ 60-

741.44(d)

Reasonable

accommodation

to physical and

mental

limitations.

A. Does your organization have written reasonable accommodation

procedures? (**These are not required but are considered a best

practice.)

A. ___YES ___NO

§ 60-

741.44(e)

Harassment.

A. Has your organization developed procedures to ensure that its

employees are not harassed on the basis of disability?

B. Has your organization implemented procedures to ensure that its

employees are not harassed on the basis of disability?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

A. Does your organization undertake appropriate outreach and

recruitment activities such as those listed below that are reasonably

designed to effectively recruit qualified individuals with disabilities?

B. Does your organization send written notification of company policy

related to its affirmative action efforts to all subcontractors, including

subcontracting vendors and suppliers, requesting appropriate action

on their part?

Examples of Outreach and Recruitment Activities:

A. Has your organization enlisted the assistance and support of local,

state and national organizations in recruiting and developing on the

job training opportunities for individuals with disabilities to fulfill your

commitment to provide equal employment opportunity for individuals

with disabilities?

A. ___YES ___NO

B. ___YES ___NO

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Activities (continued)

Has your organization enlisted the assistance and support in your area

of:

A. State vocational rehabilitation agency?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

B. State mental health agency?

C. State developmental disability agency?

B. ___YES ___NO

C. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area

of:

A. Employment One-Stop Career Center (One-Stop) or American Job

Center?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area

of:

A. The Department of Veterans Affairs Regional Office?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area:

A. Employer Assistance and Resource Network (EARN)?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area

of:

A. Local Employment Network Organizations?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area

of:

A. Local disability groups or organizations?

B. Centers for Independent Living (CIL)?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area

of:

A. Placement or career offices of educational institutions that

specialize in the placement of individuals with disabilities?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

Has your organization enlisted the assistance and support in your area

of:

A. Private recruitment sources, such as professional organizations or

employment placement services that specialize in the placement of

individuals with disabilities?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

A. Has your organization held (or planning to hold) formal briefing

sessions, preferably on company premises, with representatives from

recruiting sources?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

B. Do the formal briefing sessions your organization has organized (or

is planning to organize) for representatives from recruiting sources

include:

• B1 Facility tours,

• B2 Clear and concise explanations of current and future job

openings, position descriptions, and worker specifications,

• B3 Explanations of the company's selection process, and

• B4 Recruiting literature?

C. Is your organization’s official in charge of your affirmative action

program in attendance (or planning to be in attendance) at briefing

sessions for recruiting sources?

D. Is your organization developing (or planning to develop) formal

arrangements with recruiting sources for:

• D1 referral of applicants,

• D2 follow up with sources, and

• D3 feedback on disposition of applicants?

B1. __YES ___NO

B2. __YES ___NO

B3. __YES ___NO

B4. __YES ___NO

C. __YES ___NO

D1. __YES ___NO

D2. __YES ___NO

D3. __YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

A. Do your organization’s recruitment efforts at all educational

institutions incorporate specific efforts to reach students who are

individuals with disabilities?

A. __YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

A. Is your organization making an effort to participate in work-study

programs for students, trainees, or interns with disabilities?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

A. Are individuals with disabilities made available for participation in

career days, youth motivation programs, and related activities in their

communities?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

A. Does your organization take any other positive steps it deems

necessary to attract individuals with disabilities not currently in the

work force who have requisite skills and can be recruited through

affirmative action measures?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

Examples of Practices (continued)

A. When making hiring decisions, does your organization consider

applicants who are known to have disabilities for all available positions

for which they may be qualified when the position(s) applied for is

unavailable?

A. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

A. Does your organization on an annual basis review the outreach and

recruitment efforts it has taken over the previous 12 months to

evaluate their effectiveness in identifying and recruiting qualified

individuals with disabilities?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

B. Does your organization document each evaluation, including at a

minimum, the criteria it used to evaluate the effectiveness of each

effort and the contractor's conclusion as to whether each effort was

effective?

C. Does your organization maintain the two previous questions’ data

on the effectiveness of each of its outreach and recruitment efforts for

the current year and the two most recent previous years?

D. In light of these regulations, does your organization reasonably

conclude that the totality of its outreach efforts are effective?

E. If your organization concludes that the totality of its efforts were

not effective in identifying and recruiting qualified individuals with

disabilities, does it identify and implement alternative efforts as listed

in 60-741.44 (f)(1) or (f)(2) of the regulation in order to fulfill its

obligations?

B. ___YES ___NO

C. ___YES ___NO

D. ___YES ___NO

E. ___YES ___NO

§ 60-

741.44(f)

External

dissemination of

policy, outreach

and positive

recruitment.

A. Does your organization adhere to the recordkeeping obligation of

the affirmative action program by documenting all activities it

undertakes to comply with the obligations of this section?

B. Does your organization retain these documents for a period of three

(3) years?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Does your organization internally communicate its affirmative

action obligation to create a strong outreach program to employ and

advance in employment individuals with disabilities?

B. Are activities to create a strong outreach program to employ and

advance in employment individuals with disabilities supported by

executive, management, supervisory and other employees?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Is the obligation to create a strong outreach program to employ and

advance in employment individuals with disabilities included in your

policy manual?

B. If no, have you made the policy available to your employees by

other means?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. If your company is party to a collective bargaining agreement, have

you notified union officials and/or employee representatives of your

obligation to engage in affirmative action efforts to employ and

advance in employment qualified individuals with disabilities and

requested their cooperation?

A. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Have you informed all employees and prospective employees of

your commitment to engage in affirmative action efforts to employ

and advance in employment qualified individuals with disabilities?

(This practice and the remainder of the practices described below

under internal dissemination of policy are encouraged but not

required.)

B. Are you periodically scheduling meetings with all employees to

inform them of your commitment to engage in affirmative action

efforts to employ and advance in employment qualified individuals

with disabilities?

A. ___YES ___NO

B. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(g)

Internal

dissemination of

policy.

C. Have you explained individual employees’ responsibilities to engage

in affirmative action efforts to employ and advance in employment

qualified individuals with disabilities?

C. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Have you publicized your commitment to engage in affirmative

action efforts to employ and advance in employment qualified

individuals with disabilities in your company newspaper, magazine,

annual report and other media?

A. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Have you conducted specific meetings with executive,

management, and supervisory personnel to explain the intent of your

commitment to engage in affirmative action efforts to employ and

advance in employment qualified individuals with disabilities and

individuals’ responsibility for effective implementation making clear

the chief executive officer's support for the affirmative action policy?

A. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Have you discussed your commitment to engage in affirmative

action efforts to employ and advance in employment qualified

individuals with disabilities in both employee orientation and

management training programs?

A. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. Are you including articles on accomplishments of individuals with

disabilities in company publications?

A. ___YES ___NO

§ 60-

741.44(g)

Internal

dissemination of

policy.

A. When employees are featured in employee handbooks or similar

publications for employees, is your organization including individuals

with disabilities?

B. Are all of these procedures and activities to engage in affirmative

action efforts to employ and advance in employment qualified

individuals with disabilities designed to foster understanding,

acceptance and support among your organization’s executive,

management, supervisory, and other employees and to encourage

such persons to take the necessary actions to aid your organization in

meeting this obligation?

A. ___YES ___NO

B. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Has your organization designed and implemented an audit and

reporting system to measure the effectiveness of your affirmative

action program to employ and advance in employment qualified

individuals with disabilities?

A. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Does your audit and reporting system measure the effectiveness of

your affirmative action program?

A. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Does your organization’s audit and reporting system indicate any

need for remedial action?

A. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Does your organization’s audit and reporting system determine the

degree to which your affirmative action objectives have been

attained?

A. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Does your organization’s audit and reporting system determine

whether known individuals with disabilities have had the opportunity

to participate in all company sponsored educational, training,

recreational, and social activities?

A. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Does your organization’s audit and reporting system measure your

compliance with the affirmative action program's specific obligations?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.44(h)

Audit and

Reporting

System.

Does your organization document the actions taken to comply with

these audit and reporting obligations? And does your organization

retain these documents as employment records subject to the

recordkeeping requirements of § 60-741.80?

A. ___YES ___NO

§ 60-

741.44(h)

Audit and

Reporting

System.

A. Did your organization undertake necessary action to bring the

affirmative action program into compliance if it was found to be

deficient as a result of the self-audit?

A. ___YES ___NO

§ 60-741.44(i)

Responsibility

for

implementation.

A. Has your organization assigned an official of your organization to be

responsible for implementation of your affirmative action activities to

employ and advance in employment qualified individuals with

disabilities?

B. Does the assigned official’s identity appear on all internal and

external communications regarding the company's affirmative action

program?

C. Has this official been given necessary senior management support

and staff to manage the implementation of the affirmative action

program?

A. ___YES ___NO

B. ___YES ___NO

C. ___YES ___NO

§ 60-741.44(j)

Training.

A. Has your organization trained all personnel involved in the

recruitment, screening, selection, promotion, disciplinary, and related

processes to ensure implementation of the commitments in the

contractor's affirmative action program?

A. ___YES ___NO

§ 60-

741.44(k)

Data Collection

Analysis.

Does your organizations document the following computations and

comparisons on an annual basis and maintained these data for a

period of 3 years?

A. The number of applicants who self-identified as individuals

with disabilities pursuant to § 60-741.42(a), or who are

otherwise known to be individuals with disabilities

B. The total number of job openings and total number of jobs

filled

C. The total number of applicants for all jobs

D. The number of applicants with disabilities hired for all jobs

E. The total number of applicants hired for all jobs

A. ___YES ___NO

B. ___YES ___NO

C. ___YES ___NO

D. ___YES ___NO

E. ___YES ___NO

§ 60-

741.45(a)

Goal.

If organization has 100 or fewer employees:

A. Does your organization either apply a 7% utilization goal across the

entire workforce OR for each job group (or trade group) in the

organization’s workforce?

If organization has more than 100 employees:

A. Does your organization apply a 7% utilization goal for each

job group (or trade group) in the organization’s workforce?

A. ___YES ___NO

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-

741.45(d)

Utilization

analysis.

If organization is applying utilization goals for each job group (see

above).

A. Is your organization applying the same job groups established for

utilization analysis under Executive Order 11246, either in accordance

with the supply and service contractor requirements at 41 CFR 60-

2.12, or in accordance with the construction contractor requirements

at 41 CFR part 60-4, as appropriate?

A. ___YES ___NO

___N/A

§ 60-

741.45(d)

Utilization

analysis.

A. Is your organization annually evaluating its utilization of individuals

with disabilities in each job group?

A. For those contractors with 100 or fewer employees, is your

organization annually evaluating its utilization of individuals with

disabilities in your entire workforce (permitted instead of using job

categories)?

A. ___YES ___NO

§ 60-

741.45(e)

Identification of

problem areas.

A. When the percentage of individuals with disabilities in one or more

job groups, or in your organization's entire workforce, is less than the

utilization goal, does your organization take steps to determine

whether and where impediments to equal employment opportunity

exist?

B. When making this determination, does your organization assess its:

B1. Personnel processes?

B2. The effectiveness of its outreach and recruitment efforts?

B3. The results of its affirmative action program audit?

B4. Any other areas that might affect the success of the affirmative

action program?

A. ___YES ___NO

B1. __YES ___NO

B2. __YES ___NO

B3. __YES ___NO

B4. __YES ___NO

§ 60-

741.45(f)

Action-oriented

programs.

A. When the organization identifies problem areas, does it develop

and execute action-oriented programs designed to correct any

identified problem areas?

A. ___YES ___NO

§ 60-

741.46(a)

Voluntary

affirmative

action programs

for employees

with disabilities.

A. Does your organization recognize that it is permissible to develop

and implement voluntary training and employment programs for

people with disabilities?

A. ___YES ___NO

§ 60-

741.46(a)

Voluntary

affirmative

action programs

for employees

with disabilities.

A. Does your organization have a voluntary affirmative action program

for employees with disabilities?

B. If so, does your organization include an annual report describing

your voluntary affirmative action program and the outcomes achieved

in your affirmative action program?

A. ___YES ___NO

B. ___YES ___NO

___N/A

Regulation

Section

Regulation

Title

Compliance Questions

Compliance

Responses

§ 60-741.47

Sheltered

workshops.

A. If your organization has contracts with sheltered workshops, does it

understand that

• Contracts with sheltered workshops do not constitute

affirmative action in lieu of employment and advancement of

qualified individuals with disabilities in the contractor’s own

workforce?

• If a sheltered workshop is training people to be employees of

your organization, such trainees are not to be included in

your organization’s utilization analysis or counted toward the

7% goal because they are not part of your organization’s s

workforce

• Only after the trainees become employees of your

organization, and are receiving the same compensation as

other employees, may you count these employees toward

your utilization goal.

B. If your organization pays some of its own employees under a FLSA

14(c) certificate, does it understand that

• If the organization has over 100 employees, it can only count

these employees toward the goal for the job group in which

they are employed.

A. ___YES ___NO

___N/A

B. ___YES ___NO

___N/A