To encourage more federal contractors to prepare a Functional Affirmative Action Plan (FAAP), the US Department of Labor’s division, Office of Federal Contract Compliance Programs (OFCCP), has made major revisions to Directive 2013-01 Revision 1.
Fundamental Changes to Functional Affirmative Action Plan
- The agreement has been extended from a three-year term to a five-year period.
- Contractors with FAAP agreements are no longer required to be submitted to one compliance evaluation during the agreement’s five-year term.
- A covered contractor’s compliance history will no longer be a factor when being considered for a FAAP agreement or termination.
- The term between compliance audits has been increased to three years, up from two years, for a single functional unit.
- OFCCP will now review FAAP applications within 60 days.
Overall, the directive’s revisions make it less prohibitive than the OFCCP’s initial guidance back in 2011 (read article). However, FAAPs expose a larger portion of a company’s workforce to OFCCP audits.