What Goes Into An OFCCP AAP

By Scott Martin


The Office of Federal Contract Compliance Programs requires qualified contractors and subcontractors to create an Affirmative Action Plan. An OFCCP AAP is required 120 days after a federal contract has been given to an employer. It is made to ensure that minorities, veterans, women, and PWDs are given equal access to employment opportunities like the rest of the workforce recruited by a specific employer.

All federal contractors with at least fifty employees are mandated to pass an AAP. Additionally, they must hold a contract amounting to at least fifty thousand dollars. Depositories of funds from the government and financial institutions serving as paying and issuing agents for savings notes and savings bonds are authorized to make this action plan.

Qualifiers of the aforementioned criteria are responsible for adhering to an OFCCP prescribed method of hiring and recruiting, as well as, analyzing and tracking employment compensation or data. Qualifiers of building an AAP are subjected to random evaluations from the OFCCP. If violations are caught, the company is given a period of time to correct any offenses made as an attempt at a resolution from the OFCCP.

If even after the set amount of time has been given and the company still fails to comply with the rules and regulations, it can end up losing its government contract. Victims of discrimination will be compensated and the company will be banned from contracting with any government agency in the future. Moreover, they will also be liable to pay a huge sum worth of penalties and fees that will likely end up incapacitating the business.

Comprehensive documentation of files and reports is crucial in case of an abrupt evaluation. Outreach efforts must be planned by contractors to attract qualified candidates that are PWDs and protected veterans. Employers must attain a benchmark of 7% for PWDs and 6.9% for protected veterans. Affiliating with organizations for veterans and PWDs can help them achieve this benchmark.

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 must be customized according to the size of a company and the number of employees that it maintains. They must reflect the organizational structure, policies, practices, and programs employed by the contractor. Documents indicating employment policies and practices, as well as, materials involved in affirmative action efforts must be kept as evidence of compliance.

Federal contractors need to follow a long list of regulations in order to guarantee equal opportunities for everyone. Figures show that approximately four hundred hours is spent annually by large companies on regularly maintaining and updating their AAPs. The hours spent by administrative and management departments on tracking affirmative action programs accumulate to a grand total worth fifteen thousand dollars in resources.

Seminars and even training programs are presented by the OFCCP for companies that need assistance in complying with these complex regulations. Companies may even hire expert legal teams to work around any issues that OFCCP compliance might pose. Huge consequences are on the line for companies that exhibit noncompliance, but even if this is the case, employers must genuinely extend a hand to give minorities chances for employment regardless of whether it is required of them or not.




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