2013 has been a very busy year for the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP). With the release of revised regulations regarding veterans and persons with disabilities in September and the agency’s changing procedures for investigating potential compensation disparities, federal contractors and subcontractors are spending much of their time focusing on these areas. Even with these significant changes, though, companies need to realize the importance of having good affirmative action plans.
Most federal contractors and subcontractors will produce two affirmative action plans (AAPs) for each establishment or functional unit. One affirmative action plan will deal with OFCCP’s regulations regarding minorities and females; the other affirmative action plan will deal with OFCCP’s regulations regarding veterans and persons with disabilities. Some companies will combine all affirmative action plans into one docu