Functional affirmative action plans (FAAPs) are not new.  While the regulations require AAPs be prepared on an establishment-basis, OFCCP has permitted contractors to structure their AAPs by “function” or “business unit” – with Agency approval.

Implicitly, the Agency’s 2013 Directive on the subject recognized that business structures had evolved since the 1960s.  Establishment-centered chains of

Has your organization ever considered switching from “establishment” AAPs to functional affirmative action plans (“FAAPs”)?  OFCCP wants contractors to consider moving to FAAPs and, in that spirit, is looking to make FAAPs more attractive by proposing new FAAP requirements that would lighten the burden for those who apply for, and those that already have, FAAP

OFCCP has received approval from OMB for revisions to the Agency’s Functional Affirmative Action Program (FAAP) directive.  The revised Directive 305 went into effect on April 28, 2016.  In response to public comments received, OFCCP made modifications to its proposed revised directive, as reflected in the supporting statement filed with OMB.

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