Why Contractors Need To Build An OFCCP AAP

By Scott Martin


Contractors working for the federal government are authorized by the Office of Federal Contract Compliance Programs to submit Affirmative Action Plans. 120 days after being granted a federal contract, the employer must submit an OFCCP AAP. It helps guarantee that minorities, PWDs, veterans, and women get to enjoy the same opportunities for employment that the full workforce of a company also gets.

All federal contractors and subcontractors with fifty employees or more are required to create an AAP. They must also have a contract worth fifty thousand dollars or more. Those serving as depositories of government funds and financial institutions functioning as issuing and paying agents for savings bonds and savings notes are required to create an action plan.

Those that apply to the aforementioned criteria must follow OFCCP prescribed methods of recruiting and hiring, as well as, tracking and analyzing employment compensation and data. The OFCCP orders random evaluations of audits of those required to build an AAP. If caught with noncompliance, the OFCCP attempts to give a resolution by offering the company a second chance to correct its violations under a given period of time.

If the company ends up failing to comply even after the given period, it can lose its government contract. The company can be prohibited from any government agency onwards. Compensations will also be given to victims of discrimination. Moreover, the company could be liable to settle penalties and fees amounting to a huge sum that could end up crippling the business.

Thorough documentation of reports and files is important in the case of an unexpected audit. Contractors must plan outreach efforts to attract qualified applicants that are protected veterans and PWDs. By affiliating themselves with veteran and disabled organizations, employers must obtain the required benchmark of 6.9% for veterans and 7% for PWDs.

These outreach programs are also expected to produce results. Figures for job openings, candidates for all positions, veteran applicants, veterans hired, and overall applicants hired are included in the process of documentation because these will eventually be evaluated by the agency. Three years is the recommended span of time that these records must be maintained.

AAPs should be built based on the size of the company and all the employees in its workforce. The organizational structure, practices, programs, and policies must be reflected in the AAP. Documents indicating these policies and practices and materials used in affirmative action programs will be used to serve as evidence of efforts to adhere to the regulations.

A litany of regulations is followed by federal contractors to secure employment opportunities for all qualified candidates regardless of any disposition. Four hundred hours is the estimated figure spent by large companies annually on keeping their AAPs updated and regularly maintained. Administrative and management branches also reportedly spend fifteen thousand dollars worth of resources in the hours drained poring over the action plan.

To help expedite this entire process, the OFCCP offers information, seminars, and training programs to advise companies on the important list of things to know about complying with all their regulations. Of course, companies may also hire the services of management and legal teams to help them with their outreach programs and OFCCP compliance. Despite all the costs and labor that goes into efforts of reducing discrimination in the workforce, employers must genuinely reach out to these minorities to give them a chance at a better life through employment.




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