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AAP recording for staff agencies

Anonymous - Jun 15, 2017
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I am a little confused if my company needs to create an AAP. As a staffing agency we place individuals on an as needed basis to our clients who happen to be government subcontractors. For the positions that require a clearance we are listed on the DD 254 as the subcontractor, since we hold the clearances. To my understanding below are the requirements needed to complete an AAP. We as a staffing agency do not have any direct federal contracts or subcontracts with guaranteed funding. Nor do we bill the government directly for labor hours worked by our temporary individuals. We invoice the client, and they provide payment directly to us in the form of a company “logo” check. So as a staffing agency would we need to create an AAP?

-50 employees/$50,000 Federal contracts or
subcontracts
-Government bills of lading totaling $50,000 or
more in 12 months

1 Answer

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