Affirmative Action Plans for Federal Contracts [+Video]

Feb 28, 2022 3:04:05 PM / by Christie Jackson

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New Web Portal Now Open

It is a new year, and it brings with it new requirements and procedures for Federal Contractors. The DOL/OFCCP have a renewed focus on compliance with Affirmative Action Plans and here are some of the high-level details.  

On December 2, 2021 the Office of Federal Contract Compliance Programs (OFCCP) announced a new online portal (“OFCCP Contractor Portal ”).   The Contractor Portal is now open for registration and here are a few of the important dates to monitor.

  • March 31st - Federal contractors will be able to log in and certify the status of their Affirmative Action Plans (AAP) for each applicable establishment and/or functional unit.
  • April 12th - The 2021 EEO-1 Component 1 Data Collection starts
  • May 17th Deadline to file the 2021 EEO-1 Report
  • June 30th - The certification period ends, and Federal Contractors will need to make the appropriate certifications in the portal.

Contractors have already been making AAP certifications on the System for Award Management (SAM), but OFCCP is ramping up efforts to make sure applicable contractors have the proper plans in place while enforcement can be managed through one online portal.

The registration process was easy if you follow the steps outlined by the OFCCP; and here is what the new portal looks like.

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Am I required to have an Affirmative Action Plan?

In simple terms, if your contract is over $50,000 and have over 50 employees it is important to know what is required and when. However, any contracts over $10,000 have requirements including but not limited to contract clauses and disclosures. As there is a lot of confusion on who is required to have an AAP plan in place, the DOL provides an Infographic that is helpful to start the process to understand compliance requirements.

What should I do now? 

This is a compliance exercise and the OFCCP estimates it takes an average of 193.6 labor hours to develop, maintain and perform the annual updates. This number will grow, as the size and locations of the company grow.  At this time, we don’t know exactly what the Contractor Portal will require for certifications but as news develops, we will keep you updated.   Until then, getting your Affirmative Action Plan documents in order will be time well spent. Requirements will vary by size of contract, industry, employee count, and other factors.

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Christie Jackson

Written by Christie Jackson

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