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ARTICLE · 23 MAY 2016

OFCCP Publishes Revised FAAP Directive

Ford Harrison LLP
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The Office of Federal Contract Compliance Programs (OFCCP) has published a revised directive regarding the use of Functional Affirmative Action Plans (FAAPs).

United StatesGovernment, Public Sector
Linda Cavanna-Wilk
Linda Cavanna-Wilk
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The Office of Federal Contract Compliance Programs (OFCCP) has published a revised directive regarding the use of Functional Affirmative Action Plans (FAAPs).  A FAAP requires specific OFCCP approval and is a departure from the typical "establishment-based" AAP structure for multi-establishment facilities, using an AAP structure that is more in line with the business functions or business units of the contractor.  A functional or business unit refers to a component within an organization that operates autonomously in the ordinary course of the organization's business.  To be considered suitable for a FAAP, the functional or business unit must: 1) currently exist and operate autonomously; 2) include at least 50 employees; 3) have its own managing official; 4) have the ability to track and maintain its own personnel activity.   

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