Affirmative Action Program (AAP) Verification Initiative

by Ryan Orr on September 4, 2018

in Affirmative Action,Alert

audit checklist

If you’re a federal contractor or subcontractor – this is important.

Is updating your AAP each year a high priority item in your organization? When it is finally updated, does it get discussed with management, and does executive leadership talk about the results and how it may inform the organization’s policies, procedures, and practices?

OFCCP thinks the answer to this question is no, and they may be correct, given that 85% of federal contractors who are sent an audit scheduling letter cannot produce an updated affirmative action plan within 30 days.

And why would contractors prioritize this? The only way OFCCP would know if a contractor was not in compliance is if it is selected for an audit, which is statistically unlikely. Given all the other competing priorities in an organization, AAPs understandably take a backseat.

Soon, that will no longer be the case.

One of the most important new initiatives from OFCCP is the Affirmative Action Verification Program, which is essentially a way of ensuring that federal contractors actually do their AAP each year. OFCCP envisions the verification will initially require a contractor certification that the plan is completed. Eventually, OFCCP will perform compliance checks on the contractor. And finally, OFCCP anticipates requiring annual submission of contractor AAPs. OFCCP intends to tie this verification process to their audit scheduling, and contractors who have not certified or submitted their AAPs will be more likely to be selected for an audit.

This is a monumental change for organizations that do not treat their AAP as a priority.

For help with your federal contracting obligations, including affirmative action plans and audits, give us a call.

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