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In general, employers who conduct business with the federal government need to develop an affirmative action plan. There are other circumstances where employers develop AAP plans outside of federal contractors. This could be the result of a court order to remedy past discrimination or as a voluntary measure. For purposes of this article we’ll focus on federal contractors and their affirmative action needs.

Laws Governing AAP

As a federal contractor or subcontractor, you are required to meet basic affirmative action and equal employment opportunity regulations. Multiple laws have been enacted which impact federal contractors and their affirmative action and EEO hiring practices. They include the Rehabilitation Act, of which Section 503 requires affirmative action for individuals with disabilities. The Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), established in 1974, also mandates that those doing business with the government ensure their job openings reach qualified Vietnam era veterans returning home from the war and ensure there is no discrimination in the hiring process. In 2002, the Jobs for Veterans Act (JVA) amended the order to include special disabled and disabled veterans, veterans who have enlisted in the Armed Forces and those in the active reserves or National Guard.

How to Implement AAP

As it relates to federal contractors in particular, the Office of Federal Contract Compliance Programs (OFCCP) monitors these requirements via its compliance mandates.

OFCCP compliance stipulates that those federal contractor or subcontractor with contracts totaling $10,000 or more, need to comply with mandatory job-listing requirements. JVA amended the order, and increased this to contracts totaling $25,000 or more. Also, if you have 50 employees or more and have contracts in excess of $50,000 or more you are also required to develop an affirmative action plan that centers on hiring, training and promoting veterans.

OFCCP compliance requires that job vacancy announcements reach state employment agencies, and in turn qualified applicants representing minorities, veterans, women and people with disabilities. Each state has its own unique career site, method of accepting job postings and record keeping data requirements. Federal contractors need to prove that they are actively working with state career sites, posting jobs and keeping records of applicants relative to minority or veteran status.

Also, preparing hiring data for reporting regulations is important to compliance. It is imperative that employers proactively maintain data on job postings and have this data available for submission should they be required to do so during an audit, and on an annual basis. The collection, storage and reporting of online job applicant data is a key mandate to meet OFCCP compliance.

For more information on OFCCP, visit


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