NT Lakis lawyers filed written comments this week with the White House Office of Management and Budget (OMB) on proposed changes the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) wants to make to its Functional Affirmative Action Program (FAAP) in conjunction with OFCCP’s request to continue the FAAP program for another three years. OMB approval of OFCCP’s request is required under the federal Paperwork Reduction Act (PRA).

Our comments first note that FAAP agreements have been beneficial to both federal contractors and their employees as well as OFCCP, and urge OMB to approve continuation of the program. At the same time, we urge OMB to modify OFCCP’s request to remove unnecessarily burdensome provisions that would otherwise require contractors seeking FAAP approval or renewal to provide extraneous information regarding their federal contracts, personnel policies and procedures, and subsidiaries.