Affirmative Action Plan (AAP)

What Is an Affirmative Action Plan (AAP)?

An affirmative action plan (AAP) is a plan or program that outlines a federal contractor or subcontractor’s efforts to provide equal employment opportunities and generally support the advancement of employees regardless of gender, race, disability, or veteran status.

Affirmative Action Plan Requirements

Formal affirmative action plans are only required for federal contractors and subcontractors.

There are additional conditions set forth by the Office of Federal Contracts Compliance Programs (OFCCP), which oversees federal contractor compliance. Their conditions include all non-construction federal contractors or subcontractors who:

• Have 50 or more employees
• Are within 120 days from the start of the federal contract
• Have a federal contract or subcontract of at least $50,000
• Have government bills of lading totaling at least $50,000 in any 12 months
• Serve as a depository of federal funds in any amount
• Or are a financial institution that is an issuing and paying agent for U.S. savings bonds and savings notes

Check with the OFCCP if you meet these conditions.

Affirmative Action Compliance

AAPs are monitored by the OFCCP at the federal level and must be updated in its online contractor portal annually. Multiple users from each organization can register on the portal to manage records if needed. Contractors that don’t certify their AAPs annually are more likely to be audited by the OFCCP.

Some states have additional AAP compliance requirements. Check with your state’s Department of Labor or Employment’s exact specifications.

In addition to having a written, up-to-date plan, the OFCCP also recommends keeping records as evidence of its affirmative action efforts, such as:

• Documents that state its employment policies and practices, such as collective bargaining agreements
• Letters sent to suppliers, vendors, and recruiters stating its affirmative action policies
• Contracts that contain equal employment clauses

AAP Reporting

According to the OFCCP, contractors should employ internal audits and reporting systems to keep track of relevant employee demographic information, monitor anti-discrimination initiatives, and analyze the effectiveness of any affirmative action plan.

Information to collect includes:

• Applicant and employee demographics collected voluntarily during the hiring process with an applicant flow log
• Promotions
• Transfers
• Terminations
• Compensation

To be clear, an AAP is the written document of the plan and policies that will guide the company forward over the next year, not the audit or reporting system that the company uses. However, it relies on the results and data collected from both.

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