As the June 29 filing deadline approaches for federal contractors to certify that they have Affirmative Action Programs (AAPs), CWC’s staff experts facilitated a virtual members-only roundtable April 27 to discuss “Affirmative Action Program Verification Interface” (AAP-VI) compliance issues.
Topics discussed at the roundtable included:
- Whether To Report Establishments or AAPs—OFCCP’s nonbinding FAQs indicate that the agency expects contractors to list all their AAPs, regardless of establishment size.
- Whether To Report Roll-up AAPs—Some contractors have been combining their establishments with fewer than 50 employees into roll-up AAPs in an effort to create plans that are large enough for meaningful analysis, but OFCCP regulations do not explicitly permit this practice unless the roll-up plan can be tied to an actual company establishment.
- Whether To Update Establishment Headcounts—OFCCP’s FAQs state that contractors should update their establishment headcounts each year, but there is no such requirement.
- How To Mark Establishments and AAPs as Closed—The contractor portal does not have a feature for deleting or removing establishments, so contractors should mark establishments or AAPs that need to be removed as “closed” in the portal.