OFCCP is breathing new life into its FAAP program, one that has been largely dormant since functional AAPs were first authorized in 2000. Many companies may now find the FAAP structure appealing. But the question remains, is the FAAP structure a good fit for your business?

What is a Functional Affirmative Action Plan?

FAAPs are not new, but they are one of the lesser-known options in OFCCP compliance. Only a small fraction of covered contractors and subcontractors choose to structure AAPs along functional lines each year.

FAAPs provide an alternative to the establishment-based AAP framework. Rather than tying plans to a specific physical location, FAAPs are structured along discrete func