In anticipation of the Labor Department’s Office of Federal Contract Compliance Programs’ (OFCCP) expected issuance soon of its proposed new Affirmative Action Program Verification Initiative (AAP-VI), we recently issued a “refresher” memo on the basics of how OFCCP establishes jurisdiction over covered federal contractors. OFCCP’s AAP-VI would require covered federal contractors and subcontractors to certify to the agency that they are complying with applicable written affirmative action program (AAP) requirements.
As we noted in our “basics” memo, our intent is to issue follow-up memos on some of the more complex OFCCP jurisdictional issues that have been and continue to be brought to our attention by member companies, starting with this memo zeroing in on the issue of how to determine if your company is an OFCCP-covered federal subcontractor.
Members of the Center for Workplace Compliance (CWC) can read more here.