NT Lakis attorneys and non-attorney professionals have created a streamlined sample AAP narrative template for protected veterans and individuals with disabilities. The narrative features elements that are aimed at making OFCCP audit submissions easier.
More specifically, the document contains sections for the disability utilization analysis, “action-oriented programs” for individuals with disabilities, and the protected veteran hiring benchmark. As a technical matter, we recognize that these three requirements fall outside the scope of “required elements” of the AAP. Because federal contractors are required to prepare these annual analyses and reports as part of their affirmative action programs, however, and OFCCP typically requests this information at the start of every compliance review, we think that including the required information in one document can make it easier to track and help facilitate compliance.
As with the model women and minorities narrative template that we recently created, our sample disability and veterans’ narrative template relegates most of the variable information to the cover page or attached appendices. Because each company’s particular practices can vary, it is important to customize the AAP narrative to fit those practices.
Members of the Equal Employment Advisory Council (EEAC) can read more here.