As a step towards the implementation of the OFCCP’s Affirmative Action Program (“PAA”) Verification Initiative, the Office of Management and Budget (OMB) approved an Affirmative Action Program Verification Interface (AAP-VI) that OFCCP developed for federal contractors to submit PAAs.
Although the verification program has not yet started and details are scarce, OFCCP already has an AAP-VI website which promises that the program is “coming soon” and explains that “the affirmative action program verification interface (AAP-VI) is a secure web interface created to improve communication and data transfer of the action program positive, between federal contractors and the Office of Federal Contract Compliance Programs. “
As previously indicated, in application of directive 2018-07, on September 14, 2020, the OFCCP published a opinion soliciting comments on its proposal to seek OMB approval to implement AAP-VI. The notice indicated that the AAP-VI would be used to facilitate an yet-to-be established online AAP certification process for federal contractors and provide a secure method for federal contractors to submit AAPs electronically to the OFCCP when they are scheduled for conformity assessment. .
Currently, federal contractors are only required to submit their PAAs by mail or email and are not required to certify annually to the OFCCP that their PAAs are compliant. According to the OFCCP AAP-VI Federal Contractor User Guide, “[t]The AAP-VI system will be the main source of entry, monitoring and submission Affirmative action programs for OFCCP review. The AAP-VI will provide federal contractors with a system to submit their programs more efficiently and provide visibility and reporting capabilities for data submitted by programs. “
We are still awaiting more details from OFCCP, we will continue to monitor and report on new developments. In the meantime, additional information is available in OFCCP AAP-VI administrative guide and OFCCP AAP-VI Federal Contracts User Guide. In addition, contractors should prepare for the launch of the verification interface by ensuring that their PAAs are prepared and ready for the “first few hours”, including ensuring that they meet all of the requirements of the OFCCP.
OFCCP takes a further step towards AAP verification
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