The Office of Federal Contract Compliance Programs has extended, for two years, its audit scheduling moratorium for specified health care entities that provide supplies and services to participants in the Veterans Affairs Health Benefits Program (VAHBP). OFCCP extended the scheduling moratorium through May 7, 2027, via Directive 2021-01 Revision 2, Extending the Scheduling Moratorium for Veterans Affairs Health Benefits Program (VAHBP) Providers.
This Directive, the first from new OFCCP Director Catherine Eschbach, amends a prior directive that extended the VAHBP audit moratorium through May 7, 2025.
During the scheduling moratorium period, VAHBP providers will be exempt from neutrally scheduled OFCCP compliance evaluations and written affirmative action program (AAP) requirements arising under Section 503 of the Rehabilitation Act and Section 4212 of the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA). VAHBP providers are still subject to their nondiscrimination obligations and discrimination complaint investigations by OFCCP. As a practical matter, the extended audit moratorium applies to entities whose only contractual relationship with the federal government comes from participation in the VAHBP.
Members of the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, can read more here.