NT Lakis attorneys and non-attorney professionals are pleased to present the first in our new “AAP Tune-Up” series.  Our launch memo focuses on the mid-year monitoring of employment selection decisions and measuring progress toward goals.

The objective of this series is to suggest tasks that can be performed right now to enhance AAPs and help ensure compliance.  Additional topics that we plan to cover in the future include reviewing EEO-1 categories, evaluating Occupational Classification Codes, and verifying job postings.

In the world of affirmative action program (AAP) compliance, the regulations enforced by the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP), as well as the Itemized Listing attached to the agency’s Scheduling Letter and its Federal Contract Compliance Manual, collectively make clear that federal contractors are expected to engage with their AAPs on a regular basis — not just annually — to include the monitoring of selection procedures and progress toward goals.  OFCCP also makes clear that it will assess whether a contractor has made these efforts during a compliance review.

Although mid-year monitoring itself is not explicitly required, it is encouraged by OFCCP as a means of helping a contractor address problems as they arise, thus helping to ensure compliance with OFCCP’s AAP requirements.

Members of the Equal Employment Advisory Council (EEAC) can read more here.