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AAP Requirements- A Technicality

Anonymous - October 6, 2022
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I’m hoping someone might be able to advise on this. I’m trying to find out if there is a date that the 50 employee threshold is based on. For example, when we file the EEO-1 report, it is based on a specific period in time of our choosing in the last quarter of the reporting year. Is there anything like this for the AAP or is it current headcount of when you would file?

We are teetering on the 50 ee threshold. Last year we did not have 50 ees, right now we do. So, when we signed Federal contracts, we didn’t have the 50+ ees that would have required us to have, and certify to having, an AAP. But, now that we have 50+ ees are we supposed to certify?

Second, if we do need an AAP and need to certify- does the 120 days a contractor has to develop an AAP start from the date they meet the requirements for needing an AAP? EX: We didn’t meet the requirements to have one when we signed contracts, but once we hit 50 employees, does the requirement automatically kick in? If yes, how do we handle the deadline for needing to certify on the portal by the end of June? Or is that requirement only for contractors who already have an AAP in place?

Thank you for your assistance!

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