Have you ever thought about making a switch to Functional Affirmative Action Programs (FAAPs) instead of the traditional establishment Affirmative Action Programs? Do your business leaders keep asking to see AAP results for the functions or business units they oversee, and not by where employees are physically located?
If the functional or business units within your organization operate independently, meaning they have their own managing official who has ultimate responsibility for the decisions made within that functional or business unit, and if those units have at least 50 employees and the ability to track and maintain their own personnel activity, then FAAPs might be an option for your organization to consider.
Before you jump ahead and make the switch, the current Directive on Functional Affirmative Action Plans (Directive 2013-01 Revision 2) is due to expire on June 30, 2022, so now would be a good time to familiarize yourself with the proposed changes to the directive, and submit your comments by April 11.
Highlights of Proposed Changes
Below is a highlight of some of changes proposed. A complete list of all the proposed changes can be found here.
Ultimately, if you decide that FAAPs are right for your organization, you will need to apply for a FAAP agreement by submitting a written request to the OFCCP Director explaining why your organization believes that FAAPs are appropriate. Plan well in advance, as OFCCP must receive your written request no later than 120 calendar days prior to the expiration of your current AAP.
If the FAAP agreement is approved by OFCCP, you then have up to 120 days from the agreement date, to implement FAAPs and finally give your business leaders their AAP results by functional or business units.