Based on findings of 2016 Government Accountability Office, close to 85% of contractor establishments did not submit an AAP within 30 days of receiving a scheduling letter. For months, the OFCCP has been working on an AAP Verification Plan that has just gone live.
On Feb. 1, 2022, contractors may begin registering for access to the new contractor portal. OFCCP will also send an e-mail to each covered federal contractor in its jurisdiction whose email information is available in its system inviting them to register. On March 31, 2022, contractors will be able to utilize the certification feature in the portal to certify their AAP compliance. By June 30, 2022, all existing federal contractors must certify whether they have developed and maintained an affirmative action program for each establishment and/or functional unit, as applicable.
HR Technology News: EngageSmart Named a 2021 Top Workplace in Massachusetts by The Boston Globe
For a federal contractor with fewer than 5,000 employees, generating a compliant Affirmative Action Plan (AAP) can put a strain on Human Resources teams. According to the OFCCP, it can take an average of 193.6 labor hours for companies to develop, maintain, and perform annual updates on their AAPs. Not only is an AAP a requirement for companies with 50 or more employees that perform work on federal government contracts valued at $50,000 or more, it is an invaluable tool to ensuring employees are not discriminated against. And, now it will be a mandate for federal contractors to certify each entity or establishment has developed and maintained an AAP.
Former OFCCP Director and Circa’s board member, Craig Leen, states, “Contractors should be following Affirmative Action Verification closely, and should make preparations to comply and verify by the June deadline. For those contractors and subcontractors who already have compliance programs and are ready to verify, this will be easy to do. For those that don’t, it’s critical to take advantage of the time provided by OFCCP to become compliant and ready.”
“This new requirement from OFCCP is a game-changer for federal contractors and those who support them. Our goal is to elevate and innovate compliance and diversity technology solutions to build workforce diversity. We have partnerships for AAP creation with companies such as DCI Consulting and Biddle Consulting Group as well as Circa’s AAP Powered by Affirmity solution to give our clients end-to-end HR solutions,” said Patrick Sheahan, CEO, Circa. “We’ve built up trust with hundreds of our clients over the past decade and have carefully selected these partners as industry best-in-class. We feel strongly that federal contractors use the AAP not just as a check-the-box compliance requirement, but also as a way to build an inclusive culture that drives innovation and revenue.”
Circa provides SaaS-based OFCCP compliance management and affirmative action planning solutions to deliver qualified candidates on a level, equitable playing field that meet organizations’ needs to build high-performing, diverse teams. Diversity and inclusion are not only proven to drive employee satisfaction but also increase revenue for employers.