The Office of Federal Contract Compliance Programs terminated all Functional Affirmative Action Program (FAAP) agreements between OFCCP and federal contractors on February 20. The agreements permitted contractors to structure their affirmative action programs (AAPs) by function rather than location.
The regulations implementing Executive Order 11246 had required federal contractors to structure their AAPs by location unless OFCCP approved a different structure. The FAAP program was the administrative vehicle for obtaining that approval. It was expected that contractors’ FAAP agreements would be terminated, however, because President Trump’s rescission of E.O. 11246 ended the regulatory framework for the FAAP program.
Covered contractors are still required to prepare AAPs under Section 503 of the Rehabilitation Act and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act.
CWC members can read more here.