As the June 30 deadline approaches for supply and service federal contractors to certify that they have developed and maintained Affirmative Action Programs (AAPs) using the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) new Affirmative Action Program Verification Interface (AAP-VI) Contractor Portal, we wanted to provide you with assistance in determining exactly what it means to have “developed and maintained” your AAPs.
Under OFCCP requirements, there are analyses that must be prepared and documented as part of the written AAP at the beginning of each AAP cycle, against those additional actions and activities by a contractor that, by definition, cannot take place in a day or even a month, and will be carried out during the AAP cycle. Our checklist provides guidance on the steps needed to complete each of these two processes in order to comply with OFCCP’s mandatory AAP-VI obligations.
Members of the Center for Workplace Compliance (CWC) can read more here.