Functional Affirmative Action Plans

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

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