This week, OFCCP published a request to extend the Functional Affirmative Action Program (FAAP) process with no changes to the existing requirements. The FAAP is an alternative to typical establishment-based AAPs; contractors provide detailed information to the agency and can receive approval to create functional, rather than geographic, plans. The current Office of Management and Budget (OMB) approval for the FAAP documents expires on April 30, and OFCCP has applied to extend the authorization for another three years.
As we continue to review OFCCP’s recently-released scheduling list and the methodology the agency used to develop the list, it appears the OFCCP will first be scheduling the 500 Compliance Checks, 83 Corporate Management Compliance Evaluations (CMCE), and 72 Functional Affirmative Action Plan (FAAP) Reviews. In the middle of the last paragraph of the OFCCP’s Methodology for Developing the Supply and Service Scheduling List FY 2019, Release-1, available at: https://www.dol.gov/ofccp/scheduling/index.html it states:
The OFCCP has announced that its next Corporate Scheduling Announcement List (CSAL), detailing which federal contractors will be listed for an OFCCP audit, will be released in mid-to-late March 2019. OFCCP is also, for the first time, releasing the CSAL exclusively in their FOIA Library and forgoing mailing letters about the upcoming audit to contractors.
RECORDED: March 2019
If you were not able to tune in for the first three webinars in the Section 503 compliance webinar series, you definitely do not want to miss this next one titled Creating Required Auditing & Reporting Process. On March 13, 2019, at 1:00 p.m. EST, Sonia Chapin, Managing Consultant and Audit Advisor at Berkshire Associates, will discuss the requirement contractors have to monitor and report on their Affirmative Action efforts for Individuals with a Disability, and the responsibility to correct for deficiencies in their program should they exist. Contractors will learn steps they can take to satisfy the requirement, including best practices for documenting the actions taken to comply. Sonia will also discuss how to respond to OFCCP’s request for records during a compliance review.
It’s that time of year again. OFCCP is getting ready to release their next list of contractors who will be subjected to a compliance review in fiscal year 2019. The agency has indicated they intend to increase the number of audits this fiscal year to 3,500. These audits may consist of compliance evaluations, compliance checks, and focused reviews. This is the first time the since fiscal year 2014 that the OFCCP has planned to schedule more than 3,000 audits.
Duration: 60 minutes
Recorded: February 2019
Presenter: Lynn Clements, Director of Regulatory Affairs
OFCCP recently announced it would conduct focused reviews of federal contractors’ Section 503 compliance during its Fiscal Year 2019 scheduling cycle. The agency also checks Section 503 compliance in every current compliance review.