• Certain federal contractors are required to develop an affirmative action program and set numeric goals for veterans and disabled applicants.

A contractor establishment required to develop and maintain a written affirmative action program (AAP) must maintain its current AAP and documentation of good faith effort, and must preserve the preceding year’s documentation, unless it was not then covered by the AAP requirement.

For any record the contractor maintains under AAP requirements, the contractor must be able to identify:

• The gender, race, and ethnicity of each employee; and
• Where possible, the gender, race, and ethnicity of each applicant.

Goals required for veterans and disabled applicants

Beginning in 2014, employers required to maintain affirmative action plans addressing veterans and individuals with disabilities were required to set numeric goals for placement of workers in these groups.

For veterans, contractors must either adopt a benchmark based on the national percentage of veterans in the workforce (6.4 percent, effective March 31, 2018) or a benchmark set by considering several factors, including the availability of veterans in the contractor's state and recent applicant and hiring ratios. This hiring benchmark functions differently from the goals in affirmative action plans for women and minorities and also the goal for individuals with disabilities. The veteran benchmark simply provides a yardstick against which contractors can measure the success of efforts to recruit and employ qualified veterans.

For individuals with disabilities, on the other hand, contractors must set a hiring goal that 7 percent of each job group be qualified individuals with disabilities. When the percentage of individuals with disabilities in one or more job groups is less than the 7 percent goal, the contractor must take steps to determine whether barriers to equal employment exist. Contractors must then develop and execute action-oriented programs to correct any identified problem areas, such as those expected for women and minorities. Again, this is not the case with the veteran benchmark.