OFCCP proposes changes to functional AAP process

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.

Our Affirmative Action Alert blog focuses on the latest news and topics affecting federal contractors and subcontractors and their compliance with affirmative action and other employment-related laws and regulations.  With breaking news, quick updates, and headlines on the Office of Federal Contract Compliance Programs and affirmative action issues, this blog is a great resource for in-house counsel, HR managers, and other compliance professionals.  Our blog is a companion to Constangy’s Affirmative Action newsletters, which address significant legislative, regulatory, and administrative proposals and changes.  Subscribe to both to stay current on these important topics!


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