OFCCP Director Craig Leen

As we are preparing for a change in leadership at OFCCP,  the Agency has published its first Section 503 Focused Reviews Annual Report and issued Section 503 Certificates of Merit.  As many are aware, OFCCP Director Craig Leen is passionate about fighting for and protecting the rights of individuals with disabilities and, as such,

OFCCP issued today the last of a series of Directives aimed at defining the Agency’s enforcement relationship with federal contractors – this Directive 2021-02 focuses on providing federal contractors “Certainty” when interacting with the Agency.

Since he took the leadership role, OFCCP Director Craig Leen has focused on providing federal contractors with “four pillars” on

As we noted in our August 2019 post, one of OFCCP Director Craig Leen’s priorities has been to update the Agency’s website with assistance materials for contractors – including Technical Assistance Guides (TAGs).  OFCCP announced today that it has updated the TAG for contractors and subcontractors with covered supply or service contracts.

TAGs

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