Is a contractor required to periodically evaluate its online application systems?
Yes. As a part of its affirmative action obligations, a contractor is required to evaluate and audit its personnel processes to determine whether it is providing equal opportunity to individuals with disabilities. Such an evaluation should encompass a review of any online application systems. At a minimum, the regulations contained in 41 CFR Part 60-2, 60-250.44, 60-300.44, and 60-741.44 require that a contractor measure the effectiveness of its affirmative action program, and ensure that its personnel processes provide for careful, thorough consideration of qualified individuals with disabilities and disabled veterans.
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