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In recent months, the Office of Federal Contract Compliance Programs ("OFCCP") has clarified that all of its compliance evaluations will include a review of a federal contractor's online application system in order to ensure that every federal contractor is providing equal opportunity to qualified individuals with disabilities and disabled veterans. The OFCCP's Directive on this issue explains that the compliance review will include whether the contractor is providing reasonable accommodation in its "online system," defined as "all electronic or web-based systems that the contractor uses in all of its personnel activities." This article addresses a federal contractor's obligations with regard to its application procedures and highlights areas in which a contractor might need to update its online system to ensure it passes the next OFCCP compliance audit.
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