OFCCP Reminds Contractors of FAAP Revisions

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

  1. The agreement has been extended from a three-year term to a five-year period.
  2. Contractors with FAAP agreements are no longer required to be submitted to one compliance evaluation during the agreement’s five-year term.
  3. A covered contractor’s compliance history will no longer be a factor when being considered for a FAAP agreement or termination.
  4. The term between compliance audits has been increased to three years, up from two years, for a single functional unit.
  5. 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.  

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