As it has done previously, OFCCP announced a three-month (August 27, 2020 to November 27, 2020) national interest exemption from AAP federal contractor obligations for “contracts entered into specifically to provide Hurricane Laura relief.” The exemption relieves these contractors from the obligations to prepare written AAPs under Executive Order 11246, Section 503 and VEVRAA.
What this means is that while a federal contract or subcontract to provide hurricane relief will not trigger the duty prepare a written AAP, the exemption does not apply to federal contractors who are otherwise obligated to prepare AAPs based on other covered federal contracts or subcontracts.
Moreover, the exemption is limited. It does not apply to obligations to:
- Not discriminate or retaliate against any protected group;
- Post the “Equal Opportunity is the Law” notice for applicants and employees;
- Maintain personnel records; and,
- List job openings with the appropriate local employment service office or American job center.