OFCCP Proposes Changes To Functional AAP Process

Constangy, Brooks, Smith & Prophete, LLP
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Constangy, Brooks, Smith & Prophete, LLP

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.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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