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e-Alert: Guidance if you Missed the June 30th Affirmative Action Plan Deadline

By August 15, 2022No Comments

Background

Federal contractors that have 50 or more employees and at least one federal contract of $50,000 are required to develop and implement an Affirmative Action Plan (AAP). An AAP plan requires Federal contractors to take proactive measures to recruit and support minorities, women, individuals with disabilities, and protected veterans within the workplace.

Back on March 31, 2022, employers were to complete an additional step with their AAP, requiring them to log into a Contractor Portal and certify the status of their AAP plan for the year. This requirement was to be completed no later than June 30, 2022.

Summary

There are three options if you missed the June 30 deadline:

  1. Employers with fewer than 50 employees that do not maintain an AAP for those employees – The certification is not required for your company.
  1. Employers that requested assistance from the Office of Federal Contract Compliance Programs (OFCCP) prior to June 30, 2022, will be considered as certifying by the deadline.
  1. Employers that have not certified their AAP should register and certify prior to September 1, 2022.If employers do not certify by September 1, 2022, this may result in future contracts not being rewarded and/or withholding contract payments.

Employer Next Steps

  • Employers that are required to file an Affirmative Action Plan and have not completed their certification should certify as soon as possible but no later than September 1, 2022, to avoid any repercussions with their federal contracts.
  • Employers should review the OFCCP Contractor Portal – Federal Contractor User Guide on this new requirement.
  • If you are interested in assistance with certifying the submission of your Company’s AAP data, please email us.
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