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8
min read
Published on
11 Jan 2022

The Impact of Rescinding Executive Order 11246 on Federal Contractors: What HR Professionals Need to Know

Published on
March 18, 2025
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Table of contents

Introduction: Navigating Changes in Federal Contractor Compliance

The recent revocation of Executive Order 11246 introduces new challenges for federal contractors, particularly in affirmative action and equal employment opportunity requirements. While certain provisions related to race, color, religion, sex, sexual orientation, gender identity, or national origin have been rescinded, critical statutory obligations under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) remain unchanged. HR professionals, legal teams, and compliance officers must adapt quickly to this evolving regulatory environment to uphold federal disability and veterans' employment requirements.

Section 503 and VEVRAA: Unwavering Compliance Obligations

Despite the changes to Executive Order 11246, requirements under Section 503 and VEVRAA remain firmly in place:

  • Section 503 of the Rehabilitation Act: Federal contractors must take affirmative action to recruit, hire, promote, and retain qualified individuals with disabilities.
  • VEVRAA: Contractors are required to provide equal employment opportunities and affirmative action for protected veterans, ensuring fair hiring and employment practices.

The Office of Federal Contract Compliance Programs (OFCCP) continues to enforce these obligations, meaning that federal contractors must consistently develop, update, and maintain affirmative action plans (AAPs) for these protected groups.

Immediate Implications for Federal Contractors

Organizations that hold federal contracts must reassess their policies and strategies to ensure ongoing compliance:

  • Affirmative Action Plan (AAP) Adjustments: Contractors must review and revise AAPs to maintain compliance with Section 503 and VEVRAA.
  • Workplace Accommodations Management: Implementing structured, automated systems for tracking and managing accommodations ensures efficiency and compliance.
  • Education and Awareness: HR professionals, managers, and leadership teams should be well-informed about their ongoing obligations.

Case Study: Compliance Challenges in the Healthcare Sector

A notable case involving the University of Pittsburgh Medical Center (UPMC) Health Plan illustrates the importance of compliance. UPMC contracted with the Office of Personnel Management (OPM) to provide health services to federal employees, with three hospitals delivering care under this plan. When the OFCCP initiated compliance reviews, the hospitals contested their status as subcontractors. However, the Administrative Review Board (ARB) ruled in favor of the OFCCP, affirming that these hospitals played a crucial role in fulfilling the federal contract and were therefore subject to compliance requirements. Read the full case study here.

The Cost of Non-Compliance

Failing to adjust to these regulatory changes can lead to serious risks for federal contractors:

  • Legal Consequences: Organizations that do not comply with Section 503 and VEVRAA may face OFCCP audits, penalties, or lawsuits.
  • Reputational Impact: Weak compliance strategies can damage an employer’s brand, affecting recruitment and employee retention.
  • Operational Disruptions: Ineffective processes and outdated tracking systems create administrative burdens and compliance gaps.

Proactive Steps for HR Professionals

Federal contractors can take several steps to strengthen their compliance efforts:

  1. Review and Revise AAPs: Ensure that affirmative action plans align with legal obligations under Section 503 and VEVRAA.
  2. Automate Compliance Processes: Using platforms like Disclo can reduce manual errors and streamline accommodations management.
  3. Conduct Employee Training: Provide clear guidance to HR teams and managers on their compliance responsibilities.
  4. Schedule Internal Audits: Routine compliance checks help identify gaps and prevent costly penalties.

Streamlining Compliance with Disclo

Managing workplace accommodations and compliance can be complex, but automation simplifies the process. Disclo’s next-generation platform enables HR teams to efficiently manage workplace accommodations, ensuring operational consistency and regulatory adherence. By integrating Disclo, federal contractors can enhance tracking, maintain compliance, and foster a more inclusive workplace.

Additional Resources for HR and Compliance Professionals

For further insights into these regulatory changes, explore the following resources:

Federal contractors that adopt proactive, technology-driven compliance strategies can mitigate risk, optimize efficiency, and maintain a strong commitment to diversity and inclusion.

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Photo of a gavel.Photo of a gavel.
Photo of a gavel.

The Impact of Rescinding Executive Order 11246 on Federal Contractors: What HR Professionals Need to Know

The recent revocation of Executive Order 11246 introduces new challenges for federal contractors, particularly in affirmative action and equal employment opportunity requirements. While certain provisions related to race, color, religion, sex, sexual orientation, gender identity, or national origin have been rescinded, critical statutory obligations under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) remain unchanged. HR professionals, legal teams, and compliance officers must adapt quickly to this evolving regulatory environment to uphold federal disability and veterans' employment requirements.

Team Disclo
March 19, 2025

Introduction: Navigating Changes in Federal Contractor Compliance

The recent revocation of Executive Order 11246 introduces new challenges for federal contractors, particularly in affirmative action and equal employment opportunity requirements. While certain provisions related to race, color, religion, sex, sexual orientation, gender identity, or national origin have been rescinded, critical statutory obligations under Section 503 of the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) remain unchanged. HR professionals, legal teams, and compliance officers must adapt quickly to this evolving regulatory environment to uphold federal disability and veterans' employment requirements.

Section 503 and VEVRAA: Unwavering Compliance Obligations

Despite the changes to Executive Order 11246, requirements under Section 503 and VEVRAA remain firmly in place:

  • Section 503 of the Rehabilitation Act: Federal contractors must take affirmative action to recruit, hire, promote, and retain qualified individuals with disabilities.
  • VEVRAA: Contractors are required to provide equal employment opportunities and affirmative action for protected veterans, ensuring fair hiring and employment practices.

The Office of Federal Contract Compliance Programs (OFCCP) continues to enforce these obligations, meaning that federal contractors must consistently develop, update, and maintain affirmative action plans (AAPs) for these protected groups.

Immediate Implications for Federal Contractors

Organizations that hold federal contracts must reassess their policies and strategies to ensure ongoing compliance:

  • Affirmative Action Plan (AAP) Adjustments: Contractors must review and revise AAPs to maintain compliance with Section 503 and VEVRAA.
  • Workplace Accommodations Management: Implementing structured, automated systems for tracking and managing accommodations ensures efficiency and compliance.
  • Education and Awareness: HR professionals, managers, and leadership teams should be well-informed about their ongoing obligations.

Case Study: Compliance Challenges in the Healthcare Sector

A notable case involving the University of Pittsburgh Medical Center (UPMC) Health Plan illustrates the importance of compliance. UPMC contracted with the Office of Personnel Management (OPM) to provide health services to federal employees, with three hospitals delivering care under this plan. When the OFCCP initiated compliance reviews, the hospitals contested their status as subcontractors. However, the Administrative Review Board (ARB) ruled in favor of the OFCCP, affirming that these hospitals played a crucial role in fulfilling the federal contract and were therefore subject to compliance requirements. Read the full case study here.

The Cost of Non-Compliance

Failing to adjust to these regulatory changes can lead to serious risks for federal contractors:

  • Legal Consequences: Organizations that do not comply with Section 503 and VEVRAA may face OFCCP audits, penalties, or lawsuits.
  • Reputational Impact: Weak compliance strategies can damage an employer’s brand, affecting recruitment and employee retention.
  • Operational Disruptions: Ineffective processes and outdated tracking systems create administrative burdens and compliance gaps.

Proactive Steps for HR Professionals

Federal contractors can take several steps to strengthen their compliance efforts:

  1. Review and Revise AAPs: Ensure that affirmative action plans align with legal obligations under Section 503 and VEVRAA.
  2. Automate Compliance Processes: Using platforms like Disclo can reduce manual errors and streamline accommodations management.
  3. Conduct Employee Training: Provide clear guidance to HR teams and managers on their compliance responsibilities.
  4. Schedule Internal Audits: Routine compliance checks help identify gaps and prevent costly penalties.

Streamlining Compliance with Disclo

Managing workplace accommodations and compliance can be complex, but automation simplifies the process. Disclo’s next-generation platform enables HR teams to efficiently manage workplace accommodations, ensuring operational consistency and regulatory adherence. By integrating Disclo, federal contractors can enhance tracking, maintain compliance, and foster a more inclusive workplace.

Additional Resources for HR and Compliance Professionals

For further insights into these regulatory changes, explore the following resources:

Federal contractors that adopt proactive, technology-driven compliance strategies can mitigate risk, optimize efficiency, and maintain a strong commitment to diversity and inclusion.

Curious to see how accommodations can support your employees?

Schedule a free demo today.
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