Roffman Horvitz Plc Past Event - Functional AAPs – Should We Seek Them and How Should We Organize Them?

Functional AAPs – Should We Seek Them and How Should We Organize Them?

Functional AAPs – Should We Seek Them and How Should We Organize Them?

2:00 p.m. - 3:00 p.m. (EDT)
American Association for Access, Equity & Diversity National Virtual Conference
Virtual Conference

Functional AAP is any affirmative action plan that is not organized by physical location. Under OFCCP's regulations, the default way to prepare AAPs is by physical location. Any contractor wishing to prepare its AAPs other than this default basis must obtain OFCCP's permission, in accordance with its 2013 directive (revised in 2016). The previous FAAP directives contained disincentives to seek functional AAP approval. For the privilege of doing your AAPs functionally, you were subject to OFCCP scrutiny of any local, state, and federal EEO violations during the previous three years and were guaranteed at least one OFCCP compliance review every three years for your organization. The new directive is significantly more attractive to employers. Many contractors would be well-served by having some or all of their organization covered by an option other than physical location-based AAPs. This includes "single-establishment" hospitals and universities.

This session will address:

  • The old FAAP directives compared to the new FAAP directive
  • The FAAP approval process, the types of information that contractors are expected to disclose in the initial application process and in response to OFCCP follow-up questions
  • Different ways to set up functional units
  • Strategic considerations for the annual preparation of the AAPs themselves
  • Strategic considerations involved in submitting a FAAP for audit versus a location-based plan for audit

PDF of Directive 2013-01 Revision 2 - RH Version - OFCCP Version

Functional Affirmative Action Programs - Frequently Asked Questions (FAQs)



Functional AAPs – Should We Seek Them and How Should We Organize Them?

The American Association for Access, Equity and Diversity (AAAED) is pleased to announce that the 46th National Conference will be launched as a six months’ virtual event beginning on June 23, 2020. Join AAAED online for our National Conference themed “Turning Obstacles into Opportunities.” In 2020, we will also acknowledge the 30th Anniversary of the Americans with Disabilities Act.

As is our tradition, every four years the AAAED National Conference is held in Washington, DC, during an election year. In this year, when we are faced with a global pandemic, AAAED has chosen to host a virtual conference – the first in its four decades' history. As is our tradition, we will feature outstanding speakers and opportunities for dialogue and networking, albeit in a unique environment.

Why do so many AAAED members return to the Annual Conference? Because they know they will be welcomed and supported in their chosen fields. Serving as equal opportunity professionals in the academic sector, private industry or government is a challenge, but AAAED members know that the association is a place where they can find advice and counsel both substantively and professionally. They can also find friendships. We activate and inspire.

Join us as we convene to Turn Obstacles into Opportunities – virtually!

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