In anticipation of the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) proceeding with its proposed new Affirmative Action Program Verification Initiative (AAP-VI), the question of whether a company is a covered federal contractor or subcontractor subject to OFCCP’s jurisdiction takes on added significance.
The proposed AAP-VI, which is in the last stages of the government’s formal approval process, would require federal contractors 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 from OFCCP that they have been flagged for a compliance evaluation.
Accordingly, we thought now would be a good time to update our primer on the basics of OFCCP jurisdiction to provide guidance to employers regarding how to determine whether your company is an OFCCP-covered contractor or subcontractor. We have also prepared and attached a corresponding infographic on OFCCP jurisdiction to further illustrate the basics of coverage.
Members of the Center for Workplace Compliance (CWC) can read more here.