To better serve federal contractors, the Functional Affirmative Action Program (FAAP) has a new directive, which includes the following updates:
OFCCP will no longer consider compliance history when reviewing a request for a new FAAP agreement or termination.
The extended agreement term is five years, up from three years.
There will be a minimum of 36 months between compliance evaluations for a single functional unit. This is 12 months longer than an establishment review.
Complete FAAP applications will be determined within 60 days. Historically, there was no deadline.
OFCCP no longer requires that FAAP contractors undergo at least one compliance evaluation during the term of their FAAP agreement.
Questions? Please email OFCCP_FAAP-UNIT@dol.gov.
Busting Myths Around Functional Affirmative Action Programs
For those out of the know, there are several myths surrounding the Functional Affirmative Action Program. However, these myths should not deter contractors from proceeding with applying for and implementing a FAAP. Here are the facts.
MYTH: FAAP agreements are burdensome to maintain because OFCCP requires updates whenever a contractor makes even a minimal change.
FACT: Contractors are no longer required to submit annual updates to their FAAP agreements. Contractors are only required to notify OFCCP when there are substantive changes that result in the addition or removal of functional units. Notification to OFCCP is due 60 days after such changes are implemented.
MYTH: The FAAP application process is burdensome and time consuming.
FACT: OFCCP streamlined the process for reviewing and approving requests for FAAP agreements as part of the new directive. Once a contractor submits a complete FAAP application package to OFCCP, a determination is issued within 60 days. During the review process, a FAAP staff member works closely with the contractor, assisting them in developing an agreement that accurately reflects how the company does business.