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The Big Picture | |
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What is an AAP?
Who is required to do Affirmative Action Planning? What are the regulations governing AAP? Who enforces AAPs and How? 1. What is an Affirmative Action Program (AAP)? As a condition of doing business with the federal government, federal contractors meeting certain contract and employment levels must prepare, in accordance with federal regulations, an Affirmative Action Program  (AAP). An AAP is a combination of statistical reports and analysis, commitments of action and descriptions of company employment policies.Fundamentally, an Affirmative Action Program is a management tool to ensure equal employment opportunity (EEO)A quick overview of an AAP based on the federal regulations is as follows:
In short, an AAP includes the policies, practices, and procedures that a federal contractor implements to ensure that all qualified applicants and employees receive an equal opportunity for recruitment, selection, advancement, and every other term and privilege associated with employment.
AAPs must be developed for:
2. Who is required to prepare an AAP?
Federal government contractors and subcontractors meeting the criteria we've listed below must create an AAP; it's a condition of doing business with the government. Some organizations for internal, political or other reasons may choose to produce a voluntary AAP. Criteria requiring an AAP Government contractors must develop and maintain AAPs for all establishments (locations) with 50 or more employees (total work force), if the contractor has a contract of at least $50,000 or more; or has government bills of lading which in any 12-month period total $50,000 or more; or, serves as a depository of Government funds in any amount; or, is a financial institution, which is an issuing and paying agent for U.S. Savings bonds or notes in any amount.(Per 41 CFR 60-1.40)This definition of a contractor would include, for example, defense contractors and companies leasing buildings to the government, banks, hospitals/medical centers, and universities. 3. What are the regulations governing AAP? Executive Order 11246 was signed into law in 1965 and forms the basis for the regulations governing the preparation of the AAP. You can access a copy of the AAP regulations at www.dol.gov. The enforcement agency, the Office of Federal Contract Compliance Programs (OFCCP), has issued a Compliance Manual for use by their staff. It interprets the regulations but is not considered, especially by those outside the agency, as the final word. 4. Who is charged with enforcement and how do they accomplish this? The Office of Federal Contract Compliance Programs (OFCCP), an agency under the Employment Standards Administration at the U.S. Department of Labor, is primarily responsible for conducting compliance evaluations of contractors' AAPs.The OFCCP has approximately 50 local offices, known as District or Area offices, under the direction of six regional offices throughout the country. Personnel in these offices, usually compliance officers, are responsible for conducting compliance evaluations . Although each government contractor must prepare and update their AAP annually, these are not automatically submitted to the government. Instead, the OFCCP selects contractors for a compliance evaluation (much like the Internal Revenue Service conducting audits) and sends a letter informing the contractor that they have been selected. The letter may request a copy of the written AAP and other data. This is reviewed at the OFCCP office as part of a desk audit and is followed by an on-site review at the contractor's facility. There are also other types of evaluations which can be used by the OFFCP to review contractor compliance with the AAP regulations.
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