Affirmative Action: New process for functional affirmative action plans

The Office of Federal Contract Compliance Programs (OFCCP) has revised the approval process for creating or maintaining optional functional affirmative action plans (AAPs). Unlike traditional AAPs, which are organized by location, functional AAPs allow employers with federal contracts to organize their data and reports by business unit (e.g., research and development, production, sales, etc.). The idea is to allow business executives to more clearly see how the company’s affirmative action goals line up with the workforce under their supervision. The downside is that the company must seek approval from the OFCCP, subjecting the AAP to additional scrutiny. Under the agency’s new procedures, approval of functional affirmative action plans will last only for three years, unless renewed. Also, at least two business units within the company must undergo an audit by OFCCP during those three years. For more information, see the OFCCP’s Directive 305 (12/17/12).