Taking (Affirmative) Action – Answering the Who, What, Why, & How of an AAP

• Janine Ordman
• May, 30 2017
• affirmative action

Compliance can be complicated, but it doesn’t have to be. That’s why Coggno has taken the initiative to address and simplify one of the more complex compliance matters with which businesses in the United States are faced: Affirmative Action. Now, before you scroll to the close button and run for the hills, stick around to read what promises to be a brief overview of Affirmative Action and some of the important things you should know if you wish to do business with the Federal Government.

Who Should Have an Affirmative Action Program (AAP) in Place?

According to the United States Department of Labor, an Affirmative Action Program (AAP) should be developed and implemented by all federal contractors and subcontractors; i.e. anyone who wishes to do business with the U.S. Federal Government. Additionally, some organizations may choose to produce a voluntary AAP for either internal or political reasons.

I’m a U.S. Federal Contractor/Subcontractor. What Should I Know About Affirmative Action?

You’ve read this far, which, we hope, means that this blog post is relevant to your business. Affirmative Action requires of you, as a Federal contractor/subcontractor to recruit, select, and advance (in addition to every other term and privilege associated with employment) the following qualified populations:

• Minorities

• Women

• Persons with disabilities

• Covered veterans

But, why? Because social disparities still exist, necessitating the implementation of a program to ensure equal employment opportunity (EEO) for the populations who have, historically, often experienced adversity and discrimination in the workplace.

• An AAP involves hosting training programs, outreach efforts, and other positive steps on the part of your business to ensure EEO in your organization.

• In order to comply, these efforts should be incorporated into the organization’s written personnel policies and be developed into an action-oriented AAP document to be implemented, kept on file, and updated on an annual basis.

• The AAP is required to detail how the organization will go about addressing any shortcomings relating to the expected number of minorities, women, disabled persons, and veterans who ought to benefit within a given organization.

• In order to be deemed effective, an AAP must further include internal auditing and reporting measures to measure the contractor’s progress based on the AAP goals they have set in line with governmental expectations.

Who Enforces Compliance?

The Office of Federal Contract Compliance Programs (OFCCP) is responsible for conducting compliance evaluations of contractors’ AAPs. Although all contractors are required to comply and update their AAPs annually, the OFCCP selects which contractors should be evaluated.

So, Where Do I Start?

Start by taking the Introduction to Affirmative Action credited course, expertly compiled by Berkshire Associates and available from the Coggno Course Library.

This course will equip you with a greater understanding of the Federal regulations governing affirmative action and the OFCCP, the reasons for compliance, the impact of non-compliance, and how to prepare for a successful OFCCP audit. To top it all off, upon completion course-takers will earn HRCI and SHRM credits, as well as a certificate.

Coggno. Training Simplified.