Just looking for a professional opinion… I have found a legal opinion on the Dept. of Labor website (specifically referring to Pell Grants) addressing whether or not grant funding is considered a federal contract for the purposes of OFCCP/AAP compliance. The funds we have primarily received in the past are WIOA funds and other job-related grant funds. Last year, though, we received a substantial grant through ARPA. We received the email from OFCCP regarding the registration on the Contractor Portal/AAP compliance. I believe that this email was sent out generically to all recipients of federal funds regardless of purpose. In the opinion letter issued in May 2019 the term contractor does not extend to arrangements in which the primary purpose is extending help or support by conferring grants or other benefits under Federal assistance programs. Can you confirm or deny my thought process that we do not have to comply with the registration or the AAP compliance. I believe, also, that, due to the fact that we are well under the 50 employee count, this also exempts us from compliance. Thank you for your time.
Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.
President and CEO, HR Unlimited, Inc.
Member Attorney, Roffman Horvitz, PLC
President, Berkshire Associates
Principal Consultant, DCI Consulting Group, Inc
Human Resources Manager, Circa
President, Carla Irwin & Associates, Inc.
Board Member, Circa
President and Founder, DCI Consulting
Former Director, OFCCP and Retired President, Ellen Shong & Associates,
Managing Attorney, Roffman Horvitz, PLC
Senior Consultant - EEO/Affirmative Action Division, Biddle Consulting Group
Lawyer, The Kaiser Law Group, PLLC
Senior Counsel, Seyfarth Shaw
Senior Consultant, Director, Biddle Consulting Group, Inc.
Former Deputy Director, OFCCP Partner, McGuireWoods LLP
Manager, Consulting Services, Affirmity
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