Ask the Experts is an exclusive online forum provided by Circa. Federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity.
I noticed on the Certification page they ask for the start date of the AAP you are certifying. I am confused about what that means exactly and I find the FAQ on that to also be confusing. See FAQ below. Can you please explain?
16. For covered government contractors with a June 1 plan start date, will OFCCP require the 2022 or 2023 AAP to be certified?
Covered federal contractors and subcontractors are required to use the OFCCP Contractor Portal to certify whether they are currently meeting their requirement to develop and maintain annual AAPs. When a contractor selects a response to the certification statement through OFCCP’s Contractor Portal, it is selecting the response that reflects its AAP status as of the date it certifies. For example, if a contractor with a June 1, 2023 AAP start date certifies when the Contractor Portal opens for certification on March 31, 2023, then the contractor would be certifying the 2022 AAP (effective June 1, 2022 through May 31, 2023). If the contractor certifies on or after June 1, 2023, it would be certifying the 2023 AAP (effective June 1, 2023 through May 31, 2024).
The start date is the beginning date of your current AAP. If June 1st is your plan start date and you are certifying prior to June 1, 2023, for example, then the start date would be June 1, 2022 with the ending date being May 31, 2023.