October 18, 2021

Volume XI, Number 291

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October 15, 2021

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OFCCP Moves Forward Towards AAP Verification

Among the many “hot” topics for federal contractors, OFCCP’s intention for AAP verification and/or certification ranks among the top.  In September 2020, OFCCP published a notice seeking comment on the possibility of an annual AAP certification and verification process.  Towards that end, the Agency also sought Office of Management and Budget (OMB) approval for an “AAP Verification Interface” (AAP-VI).

Yesterday, OFCCP cleared a major hurdle toward AAP verification with OMB’s approval of the “AAP-VI.”  Although the AAP-VI is not “live,” a page at OFCCP’s website explains:

Affirmative Action Program Verification Interface (AAP-VI) is a secure web based interface created to improve communication and the transfer of Affirmative Action Program data, between Federal Contractors and the Office of Federal Contract Compliance Programs.

Questions remain, including whether the AAP-VI will be used only for audit submissions or whether it will also be used for annual AAP certification, and whether certification will entail uploading of data.  At the current time, contractors are only required to submit an AAP to OFCCP in the context of a compliance review.

As part of its approval, OMB also approved a User Guide and an “Admin Guide.”  At 23 and 22 pages in length, respectively, there is a lot to digest in these documents but not much clarification about the context in which the information will be submitted.

In the Purpose & Scope section of the User Guide, OFCCP says:

Currently, federal contractors submit their AAPs via mail or email. The AAP-VI system will be the primary source for entering, tracking and submitting your Affirmative Action Programs for review by OFCCP. AAP-VI will provide federal contractors a system to submit their Programs in a more efficient manner and provide visibility and reporting capabilities of the data submitted by the Programs.

Jackson Lewis P.C. © 2021National Law Review, Volume XI, Number 244
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About this Author

Laura Mitchell, Jackson Lewis, Management Representation lawyer, Contractual Drafting Attorney
Principal

Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and government contractor compliance.

Ms. Mitchell is a Principal in the firm’s Affirmative Action and OFCCP Defense practice group, representing government and non-government contractors in Office of Federal Contract Compliance Programs (OFCCP) matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming...

303-225-2382
F. Christopher Chrisbens, Jackson Lewis, litigation attorney, employment law, intellectual property legal counsel, OFCCP compliance lawyer
Of Counsel

F. Christopher Chrisbens is Of Counsel in the Denver, Colorado, office of Jackson Lewis P.C. Over his years as a litigation attorney, manager, trainer and workplace investigator, Mr. Chrisbens has developed a diverse array of employment law skills serving employers in a variety of legal and corporate settings.

Mr. Chrisbens began his career as a litigator and appellate practitioner in Los Angeles, California, and later returned to Boulder, Colorado where he was partner in a Boulder firm practicing in the areas of commercial...

303-225-2381
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