The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has made a further change to its revised procedures governing its so-called Functional Affirmative Action Plan (FAAP) program that will substantially reduce the burden on some federal contractors that wish to participate in the FAAP program.
The change was made in response to comments on OFCCP’s proposed revisions that were written by NT Lakis lawyers and filed with the Office of Management and Budget (OMB), which has now given final approval to OFCCP’s revised FAAP directive. Specifically, under the change, contractors that wish to apply for FAAP approval, or renew an existing FAAP agreement, will not have to submit information to OFCCP regarding every affiliated company in the corporate family. Rather, contractors will be required to disclose information regarding only the affiliated companies that are to be included in the FAAP agreement.
An OFCCP official confirmed that the revised FAAP directive will be posted to the agency’s website sometime within the near future. The new directive will apply to contractors submitting FAAP applications and renewal requests on or after April 28, 2016.
Members of the Equal Employment Advisory Council (EEAC) can read more here.