A source of insights, news and strategy on affirmative action and EEO compliance matters
Since 2013, OFCCP has revised its Functional Affirmative Action Plan (FAAP) Directive several times, most recently to make it easier for covered federal contractors and subcontractors to obtain its permission to create AAPs by functional unit.
AAP regulations require establishment AAPs but allow for the option to prepare plans by separate “functional units,” provided…
Hello and Welcome from the Opening Day of the 2021 Industry Liaison Group (ILG) National Conference.
After a year hiatus, the 2021 ILG National Conference officially kicked off today from Nashville, TN. Offering access to programming both virtually and in person, the conference is working hard to address the realities of operating in a…
As of today, federal contractors have a new tool for understanding a variety of compliance obligations enforced by the Office of Federal Contract Compliance Programs (“OFCCP”). The Agency has launched a Contractor Compliance Institute (“CCI”) where contractors can take free, on-demand courses on a variety of OFCCP-related topics.
The CCI is designed to help contractors…
Avid readers have seen that OFCCP has been busy this summer. In August alone, the Agency attended the 2019 ILG National Conference in Milwaukee, issued FAQs on student workers, proposed a new rule regarding religious exemptions, introduced a new Ombudsperson, opened a contractor assistance portal and issued multiple technical assistance guides. But, OFCCP…
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 been busy, and they are not slowing down. Today, OFCCP issued an additional 750 Corporate Scheduling Announcement Letters (CSALs) to federal contractors providing advance notification of compliance reviews, in order to make sure the district and area offices “have a sufficient number of available establishments to schedule for compliance reviews until OFCCP…
After two rounds of public comments, OFCCP implemented Directive No. 305 earlier this month with little fanfare. Directive 305 provides guidance to employers who desire to create affirmative action plans based on functional business units rather than by individual establishment – also known as FAAPs. Implementation of Direction 305 rescinds the previous FAAP directive, in…
