On December 2, 2021, OFCCP announced that it was launching its Affirmative Action Program Verification Initiative (the AAP VI), requiring all federal supply and service contractors and subcontractors to certify annually whether they have developed and maintained an affirmative action program (AAP) for each of their establishments or functional units. OFCCP has created a new “Contractor Portal” for contractors to make those certifications and for contractors to submit their AAPs to OFCCP during compliance evaluations.
Before now, federal contractors and subcontractors have not been required to certify to OFCCP that they have developed and maintained AAPs. Although prime contractors have to certify whether they have developed AAPs in the System for Award Management, historically, OFCCP has had no process for ensuring that contractors and subcontractors have developed and maintained AAPs for each of their covered establishments. As we previously reported, in September 2020, OFCCP sought comments on launching the AAP VI. Since then, OFCCP sought and received approval from the Office of Management and Budget for the AAP VI, including a User Guide and an Administrator Guide.
With the implementation of the AAP VI, OFCCP believes it will now have the information to ensure “that all covered contractors are meeting their obligation to develop and maintain written AAPs.” Under the new AAP VI, supply and service contractors who meet the thresholds for having to create AAPs must...
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