You hired a staffing firm to provide you with entry-level workers to manufacture screws for a three-month government contract you just won. You will not recruit, hire, fire, supervise, or discipline the employees. There might be a longer term opportunity for them after the three months if the contract gets extended. While this solution solves your labor supply concerns, you also need to consider other compliance issues. For example, what should you do when it comes to your annual Affirmative Action Plan (AAP)? Should these workers be included in your AAP?

To make this decision, you will want to examine whether these workers are considered “employees” since OFCCP regulations provide that all employees must be included in a