On Monday, Craig Leen, Acting Director of OFCCP, issued a National Exemption (NIE) Memorandum to federal contracting agencies notifying them to grant a limited exemption to new supply and service or construction contracts specifically created to provide Hurricane Michael relief. This relief effort is similar to what was done with new federal contracts to provide relief for Hurricane Florence last month.
The Hurricane Michael National Interest Exemption is effective from October 11, 2018, through January 11, 2019, (subject to extension) and waives the requirement to develop written affirmative action programs under the three OFCCP regulations, Executive Order 11246, Section 503 of the Rehabilitation Act, and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).
The same exemptions are in effect for new contracts to provide relief for Hurricane Florence dating back to September 17, 2018, through December 17, 2018. The exemptions apply only to new contractors and subcontractors. If a company already has contracts with a federal agency requiring them to complete affirmative action plans, the exemptions do not apply.
Berkshire Associates is always available to help federal contractors who need assistance with preparing compliant annual AAPs on time. If you have specific questions about how to best to prepare your AAP, please contact Berkshire Associates at firstname.lastname@example.org, or 800.882.8904.