NT Lakis, on behalf of the Center for Workplace Compliance (CWC), recently submitted written comments to the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) in response to the agency’s proposal to implement an online portal through which federal contractors would be required to: (1) certify annually that they have developed and maintained Affirmative Action Programs (AAPs) in accordance with OFCCP’s regulations; and (2) upload and submit their written AAPs in response to notice of a compliance evaluation.
The so-called Affirmative Action Program Verification Interface (AAP-VI) was developed due in part to the fact that OFCCP estimates that it only evaluates approximately two percent of all federal contractor establishments each year. The comments note that as a practical matter, as some of the nation’s largest federal contractors, CWC’s members represent a significant portion of this “two percent” each year. Thus, to the extent that the AAP-VI would actually shift OFCCP’s enforcement focus to a larger subset of federal contractors beyond these two percent, we generally supports what OFCCP is proposing to accomplish.
Members of the Center for Workplace Compliance (CWC) can read more here.