Often in conjunction with the beginning of a new calendar year, it is not uncommon for companies to re-evaluate their policies, procedures, and employment practices to ensure corporate goals are being achieved. For companies that are federal contractors, this process may trigger the need to establish affirmative action programs (AAPs) or to consider resetting a current “AAP cycle” or “AAP year.”
A few years ago, we prepared a memorandum that covered this topic in depth, providing guidance on the considerations that should be taken into account in deciding on the most appropriate AAP cycle, compliant with the regulations enforced by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP). Because this is a topic that continues to be brought up with our OFCCP compliance team, and in conjunction with the start of a new calendar year, we thought it might be helpful to issue this Quick Reference Guide.
Members of the Center for Workplace Compliance (CWC) can read more here.