Affirmative Action Plan (AAP)

What is an Affirmative Action Plan (AAP)?

An Affirmative Action Plan (AAP) is a written document that lays out all the guidelines, procedures, and steps that an employer will implement to ensure equal employment opportunities for all. It is a detailed program that supports the hiring and advancement of everyone regardless of an individual’s gender, race, color, age, national origin, disability, or veteran status. As per federal guidelines, an Affirmative Action Plan (AAP) is to be updated once a year. 

Do all organizations need an Affirmative Action Plan (AAP)?

No. An Affirmative Action Plan (AAP) is only required for federal contractors and subcontractors. The Office of Federal Contract Compliance Programs (OFCCP) oversees compliance to all affirmative action requirements. Several conditions have been set to see if a business needs to have an Affirmative Action Plan (AAP) in place. 

To comply with federal requirements, organizations that meet the following criteria are obligated to have an AAP:

• The company is involved with federal government contracts as a contractor or subcontractor;
• The contract is valued at $50,000 or more;
• The company employs 50 individuals or more, including those working part-time;
• The company is within 120 days from the start of the federal contract;
• The company serves as a depository of federal funds in any amount;
• The company is a financial institution for U.S. bonds and notes.

It is best to consult with the OFCCP for any concerns regarding the above mentioned conditions. 

What are the benefits of having an Affirmative Action Plan (AAP)?

Having an Affirmative Action Plan (AAP) in place benefits an organization by improving transparency in the hiring and promotion processes. It also paves the way for diversity in the work environment. 

How is an Affirmative Action Plan (AAP) monitored? 

As previously mentioned, the Office of Federal Contract Compliance Programs (OFCCP) oversees all affirmative action plans and obligations. They conduct compliance audits and on-site inspections if needed. Organizations submit their AAP and all relevant supporting data for review. These data may include hiring demographics, promotions, terminations, and compensation. 

If the OFCCP deems it necessary to have an on-site inspection, they send a review officer to gather additional data and conduct interviews as needed. Any organization that has been found to have discrimination issues and adverse impact may face penalties and consequences.