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.
When it comes to EEO Taglines, if an employer chooses to do the long version does it preclude them from being able to use the abbreviated version OR can both be used so long as they are compliant? For example, if marketing materials used the abbreviated version but the career site uses the long version – is that allowed?
You are allowed to either use the abbreviated version (e.g., EOE/veterans/disabled) or the long version which contains all of the classifications covered under EO 11246, VEVRAA and Section 503 of the Rehabilitation Act. If you at times use the abbreviated version instead of the long version, you are still in compliance.
Hi Team –
What requirement does a government contractor need to meet for posting a job that is contingent (awaiting contract award).
Thank you,
Amy
Hi Amy, thank you for your question. The answer depends on whether or not this is your company's very first federal contract or subcontract. If you don't have any existing federal contracts or subcontracts and this will be the first one if awarded, then at this current point in time, you are not yet a federal contractor, and therefore not bound by any of the obligations that attach to a federal contract. These obligations become effective only when you enter...
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