OFCCP offers contractors answers to puzzling questions.

Wondering about whether to count student workers? Or whether multiple locations can be combined into one Affirmative Action Plan? These are questions that have vexed many contractors, particularly institutions of higher education.

On September 5, the Office of Federal Contract Compliance Programs issued a Directive and a set of FAQs to address these issues.

Directive 2019-05 – Contractors' Obligations Regarding Students in Working Relationships with Educational Institutions

Colleges and universities have long struggled with deciding whether student workers should be included in their AAPs. The types of student workers and their relationships with an institution are varied and vast. For example, some student workers may be r