Tag Archives: AAP

GAO Report Assesses OFCCP Progress and Indicates Annual AAP Collection Not Far Off

By Guy Brenner and Mark A. Linscott on September 27, 2019 Posted in OFCCP

The Government Accountability Office (GAO) recently released a report (the “2019 Report”) evaluating the Office of Federal Contract Compliance Program’s (OFCCP) implementation of the GAO’s 2016 and 2017 recommendations for improving oversight of contractor compliance. The 2019 Report concludes that OFCCP has implemented only 4 of the GAO’s 11 recommended changes. The key findings and … Continue Reading

OMB Approves Revised Directive Regarding Functional Affirmative Action Programs

By Alex Weinstein and Connie Bertram on May 12, 2016 Posted in Affirmative Action Plan (AAP), OFCCP

On April 28, 2016, the U.S. Office of Management and Budget (“OMB”) approved the Depart of Labor’s revised directive regarding Functional Affirmative Action Programs (“FAAP”). The revised directive amends the procedures for applying for a FAAP and clarifies the obligations that apply to contractors with approved FAAP Agreements. The revised directive replaces the prior directive … Continue Reading

District Court Rejects Challenge to Section 503 Final Rule

By Andrew Aitchison on March 24, 2014 Posted in Disability, OFCCP

On Friday, March 21, 2014, Federal District Judge Emmet Sullivan ruled in favor of the Office of Federal Contractor Compliance Programs’ (“OFCCP”) recent rule implementing Section 503 of the Rehabilitation Act, denying a challenge by the Associated Builders and Contractors trade organization (“ABC”). As a result, OFCCP’s Rule—“Affirmative Action and Nondiscrimination Obligations of Contractors and … Continue Reading

OFCCP Publishes FAQs Addressing Implementation of the New VEVRAA and Section 503 Final Rules

By Connie Bertram on December 17, 2013 Posted in Affirmative Action Plan (AAP), Department of Labor, Employment Law, OFCCP

On December 17, 2013, the Department of Labor’s Office of Federal Contract Compliance Programs (“OFCCP”) published additional Frequently Asked Questions (“FAQs”) on the implementation of the Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) and Section 503 of the Rehabilitation Act final rules. As discussed in prior Government Contractor Compliance & Regulatory Update posts on August 27, … Continue Reading

Preparing for Future Government Shutdowns

By Connie Bertram on October 22, 2013 Posted in Employment Law, Labor Law, OFCCP

Connie N. Bertram, co-head of Proskauer’s DC Labor and Employment practice and co-head of the Government Regulatory Compliance and Relations Group, was interviewed by Metropolitan Corporate Counsel regarding the impact of the government shutdown on government contractors and the steps contractors should take in preparation for another possible government shutdown and debt default. Ms. Bertram … Continue Reading

OFCCP Rules Published in Federal Register with Effective Date of March 24, 2014

By Daniel Davis on September 24, 2013 Posted in Affirmative Action Plan (AAP), Disability, OFCCP

Today, the OFCCP’s new regulations interpreting Section 503 and VEVRAA were published in the Federal Register. The rules can be found here and here. Publication in the Federal Register sets the effective date for the rules as March 24, 2014. As previously discussed, contractors should start planning the implementation of the compliance requirements imposed by … Continue Reading

OFCCP Sets Deadline for Implementation of 2010 Census Data

By Proskauer Rose on May 16, 2013 Posted in Affirmative Action Plan (AAP), Department of Labor, OFCCP

On May 15, 2013, the Office of Federal Contract Compliance Programs (“OFCCP”) announced that covered federal contractors will have until January 1, 2014 to start using 2010 Census data for determining availability when preparing annual affirmative action plans. Contractors may continue to use the “old” census data (the Census 2000 Special EEO File) for plan … Continue Reading