On September 18, 2015, the Office of Federal Contract Compliance Programs (OFCCP) published a new infographic titled Jurisdictional Thresholds. The announcement email states it is, “aimed at assisting employers, employees, and other interested parties easily determine when OFCCP’s Executive Order 11246, Section 503 of the Rehabilitation Act (Section 503), and the Vietnam Era Veterans’ Readjustment Assistance Act regulations apply to companies doing business with the federal government.” The infographic can be found at: http://www.dol.gov/ofccp/posters/Infographics/JurisdictionalThresholds_JRFQA508c.pdf.
The infographic lists each of the three sets of regulations with two rows and two columns each. The first column is for supply and service contracts and the second is for construction contracts. The first row lists the employee count and contract amount thresholds for basic coverage and the second row lists the thresholds for AAP coverage. The infographic does not make clear that for EO 11246, basic coverage is triggered by the sum of a contractor’s contracts or purchase orders in any 12-month period, whereas amounts triggering AAP coverage are for a single contract or purchase order. For VEVRAA and Section 503, both basic and AAP coverage are triggered by the amount of a single contract or purchase order.
The basic coverage amount for the Section 503 regulations is listed as $15,000, which reflects an inflationary adjustment made by the Federal Acquisition Regulatory Council in October of 2010. A statute requires an adjustment of the Federal Acquisition Regulations acquisition-related thresholds every five years for inflation using the Consumer Price Index.
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