Comment on FR Doc # 2010-18104

I would suggest that the affirmative action letters that federal contractors send to VR agencies, or the like, which state that they are actively doing outreach, be re-thought. These letters are essentially useless. When I receive one, and follow-up with the company to inquire about job openings, I am told that they aren't hiring and that they send these letters out as an obligation - in order to meet OFCCP rules. I would recommend that federal contractors be required to send actual job openings directly to state VR agencies. I think that a measurement tool of a federal contractor's job opening submission/outreach would be documentation from the VR agency, or the like, showing who was referred or what sort of follow-up was done by the VR agency. This would certainly ensure affirmative action. Sending actual job openings to VR agencies would be a time and money saver for Federal contractors. It is my understanding that federal contractors are spending up to $8000 a year to post job openings on websites which target people with disabilities. When these job leads finally filter down to VR placement people and the person with a disability - and the job opening is followed up on - again we are told that they really don't have an opening, they are just posting the openings to meet OFCCP requirements. At least by requiring federal contractors to post job openings with VR agencies, OFCCP will know that the company is submitting legitimate job openings, is truly recruiting people with disabilities for the job vacancy and will know that VR can work directly with the federal contractor to provide qualified applicants which could be hired. We are already doing this in Alabama with some federal contractors and it really does work!