FAAPs may get less burdensome.
The Office of Federal Contract Compliance Programs is proposing changes to its functional affirmative action plan process. According to the agency's request to the Office of Management and Budget, the changes would decrease the burden for those federal contractors who develop functional AAPs as opposed to establishment-based AAPs.
Functional AAPs are developed along lines of business or other organizational units, and contractors must receive approval from the OFCCP before preparing FAAPs. The approval process has been criticized for being overly burdensome, and many contractors have foregone that option as a result.
We are reviewing the OFCCP's proposal and will provide a more in-depth analysis in the next few days.
PartnerCara co-chairs Constangy’s practice groups relating to EEO/Contractor Compliance, Reporting & Analytics, and DEI Compliance. She advises employers on proactive strategies to help avoid litigation and has defended employers ...
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