Among the many “hot” topics for federal contractors, OFCCP’s intention for AAP verification and/or certification ranks among the top.  In September 2020, OFCCP published a notice seeking comment on the possibility of an annual AAP certification and verification process.  Towards that end, the Agency also sought Office of Management and Budget (OMB) approval for an “AAP Verification Interface” (AAP-VI).

Yesterday, OFCCP cleared a major hurdle toward AAP verification with OMB’s approval of the “AAP-VI.”  Although the AAP-VI is not “live,” a page at OFCCP’s website explains:

Affirmative Action Program Verification Interface (AAP-VI) is a secure web based interface created to improve communication and the transfer of Affirmative Action Program data, between Federal Contractors and the Office of Federal Contract Compliance Programs.

As part of its approval, OMB also approved a User Guide and an “Admin Guide.”  At 23 and 22 pages in length, respectively, there is a lot to digest in these documents but not much clarification about the context in which the information will be submitted.

In the Purpose & Scope section of the User Guide, OFCCP says:

Currently, federal contractors submit their AAPs via mail or email. The AAP-VI system will be the primary source for entering, tracking and submitting your Affirmative Action Programs for review by OFCCP. AAP-VI will provide federal contractors a system to submit their Programs in a more efficient manner and provide visibility and reporting capabilities of the data submitted by the Programs.

Stay tuned as we dive into the User Guides and await further information from the Agency, including when the certification obligation will commence.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.