OMB approves functional affirmative action plan (FAAP) program


By Susan Schoenfeld, JD, Senior Legal Editor

The Office of Federal Compliance Programs (OFCCP) recently announced that its proposal to revise the agency’s functional affirmative action program for federal government contractors was approved by the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA).

OFCCP’s functional affirmative action program is designed to provide multi-establishment contractors that have large business or functional units with the option of creating AAPs that better fit their business needs.

Functional affirmative action plans (FAAPs) allow the contractor to examine whether its personnel practices and affirmative action efforts are sufficient to ensure equal employment opportunity for applicants and employees of a functional or business unit, rather than a particular establishment.

In 2011, OFCCP issued new guidance and established standard procedures for FAAP approvals. OFCCP had to put the official implementation of the FAAP program on hold earlier this year because the required submission of information by a contractor during the early stages of the application for a FAAP agreement under the new program constituted an information collection request (ICR), requiring OIRA approval prior to use.

The approved ICR may now be used by the agency, and does not need to be approved again by OIRA until the end of 2015.

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