Definition of a functional affirmative action program
An affirmative action program must be developed and maintained by each covered federal contractor/sub-contractor such as service and supply companies in accordance with 41 CFR Part 60-2.
For a majority of contractors, establishment-based affirmative actions plans are developed and maintained. However, for some multi-establishment contractors that have large business or functional units such as a Sales Division or Research and Development function that span across establishments located in different states or regions, an AAP may be developed by functional or business units. These functional AAPs or FAAPs will allow the contractor to examine whether its personnel practices and affirmative action efforts are sufficient to ensure equal employment opportunity for applicants and employees of a functional or business unit, rather than a particular establishment.
How does a company apply for an agreement of a Functional Affirmative Action Program?
Companies may apply by submitting a written request to the OFCCP Director explaining why it believes that the use of a functional affirmative action plan would be most appropriate.
This explanation should also describe in detail how the proposed functional AAPs correlate to the contractor’s specific organizational structure and include a transition plan describing the process and timing by which the organization will move from establishment-based AAPs to functional AAPs. In addition, the request must include the name and contact information of the corporate representative who will be responsible for overseeing the request for a the agreement.
The request for a functional AAP agreement must be received by the OFCCP Director no later then 120 calendar days prior to the expiration of the current corporate headquarters AAP, or within 120 days from the award of the Federal contract if this is a first-time contractor. If this timeframe is not met, the request will be denied. The contractor may resubmit its request prior to the next AAP year.
How long does the application process take?
The process may take a few months as during this time OFCCP will evaluate application materials submitted, perform background research, and may request a meeting with company officials to discuss the application and the company profile.
James Gutierrez is expert as affirmative action consultant. Human resource professionals like to receive his affirmative action plan news.
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