Keyed to the start of the new school year, the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has released a trio of new compliance assistance resources targeting educational institutions, including one aimed at Historically Black Colleges and Universities (HBCUs).
While ostensibly designed to benefit educational institutions, much of the guidance offered is applicable to all federal contractors, and may serve as a good reference point as companies begin to plan for their 2020 compliance programs, including outreach and recruitment strategies targeting women and minorities.
Indeed, included in the agency’s release is a set of frequently asked questions (FAQs) designed to assist contractors that may be thinking about preparing a so-called “campus” affirmative action program (AAP). A campus AAP combines two or more establishments into a single AAP, even if the individual establishments have 50 or more employees. While OFCCP’s regulations neither endorse nor prohibit campus AAPs, in practice some contractors have used them for many years, and OFCCP’s new FAQs now appear to grant tacit approval of this practice.
Please note that this sub-regulatory guidance does not establish any new requirements, nor is it binding on federal contractors.
The new “Back to School” resources can be found on OFCCP’s website at the following links:
- Campus-Like Settings and the Affirmative Action Program,
- Student Workers, and
- White House HBCU Initiative.
Members of the Center for Workplace Compliance (CWC) can read more here.