Why Contractors Need To Build An OFCCP AAP

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By Scott Martin


The Office of Federal Contract Compliance Programs requires qualified contractors and subcontractors to create an Affirmative Action Plan. An OFCCP AAP is required 120 days after a federal contract has been given to an employer. It is made to ensure that minorities, veterans, women, and PWDs are given equal access to employment opportunities like the rest of the workforce recruited by a specific employer.

Federal contractors with about fifty people working for them are already authorized to submit an AAP. Qualifiers must also hold a fifty thousand dollar contract. Depositories of funds and paying and issuing representatives for savings notes or savings bonds in the form of financial institutions are authorized to build this action plan.

Those that apply to the aforementioned criteria must follow OFCCP prescribed methods of recruiting and hiring, as well as, tracking and analyzing employment compensation and data. The OFCCP orders random evaluations of audits of those required to build an AAP. If caught with noncompliance, the OFCCP attempts to give a resolution by offering the company a second chance to correct its violations under a given period of time.

If the company still fails to comply even after this second chance, sanctions will be administered. Not only will they lose their government contract but the company will also be prohibited from doing any more businesses with government agencies. The victims will be compensated fairly. Additionally, the company might end up crippled after the lump sum of penalties and fees that it is liable to settle.

Comprehensive documentation of files and reports is crucial in case of an abrupt evaluation. Outreach efforts must be planned by contractors to attract qualified candidates that are PWDs and protected veterans. Employers must attain a benchmark of 7% for PWDs and 6.9% for protected veterans. Affiliating with organizations for veterans and PWDs can help them achieve this benchmark.

Moreover, results are expected of the outreach programs conducted by federal contractors. The total number of job openings and jobs filled, the total number of applicants for all jobs, the number of protected veteran applicants, the number of protected veterans hired, and the total figure of applicants hired comprise the list of documents that must be kept and updated annually. Documentation of these records must be kept intact for a time frame of three years.

AAPs must be customized according to the size of a company and the number of employees that it maintains. They must reflect the organizational structure, policies, practices, and programs employed by the contractor. Documents indicating employment policies and practices, as well as, materials involved in affirmative action efforts must be kept as evidence of compliance.

Federal contractors need to follow a long list of regulations in order to guarantee equal opportunities for everyone. Figures show that approximately four hundred hours is spent annually by large companies on regularly maintaining and updating their AAPs. The hours spent by administrative and management departments on tracking affirmative action programs accumulate to a grand total worth fifteen thousand dollars in resources.

Seminars and even training programs are presented by the OFCCP for companies that need assistance in complying with these complex regulations. Companies may even hire expert legal teams to work around any issues that OFCCP compliance might pose. Huge consequences are on the line for companies that exhibit noncompliance, but even if this is the case, employers must genuinely extend a hand to give minorities chances for employment regardless of whether it is required of them or not.




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