NT Lakis, on behalf of the Center for Workplace Compliance (CWC), has filed written comments with the White House Office of Management and Budget (OMB) in support of a request by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) to extend, with minor changes, its Functional Affirmative Action Program (FAAP) application and approval process for another three years. Periodic OMB approval to extend the FAAP process is required under the federal Paperwork Reduction Act (PRA).
AAPs are an option for qualifying federal contractors in lieu of maintaining establishment-based AAPs, and OFCCP has tweaked the program periodically since it was established, each time ostensibly to encourage contractor participation. The version of the FAAP program recently sent to OMB for final approval contains some minor burden-saving improvements to the extension proposal OFCCP published earlier this year, based in part on comments submitted to OFCCP by us. For example, federal contractors participating in the FAAP program would not be required to notify OFCCP within 60 days each time a “management official” of a functional unit is hired, terminated, promoted, or resigns.
Members of the Center for Workplace Compliance (CWC) can read more here.