March 11, 2016

Monthly Extension of the FAAP Agreement Directive

The application and approval process for entering into a Functional Affirmative Action Program (FAAP) agreement with the OFCCP is outlined in Directive 305 (renumbered to 2013-01), which became effective on December 17, 2012.

The OFCCP is currently seeking approval from the Office of Management and Budget (OMB) for its information collection request (ICR) revision titled, “Agreement Approval Process for Use of Functional Affirmative Action Programs.” As discussed in the Federal Register, this ICR “addresses the collection of information associated with the process for obtaining, modifying, updating, and renewing an agreement that allows contractors to develop and use functional AAPs.” The OFCCP has requested an increase in reporting burden from 7.6 hours per contractor (926 total) to 9.5 hours per contractor (1,427 total), which reflects the replacement of the renewal process with a certification requirement. Additionally, contractors seeking a new FAAP agreement will no longer be required to provide a copy of their Federal contract for approval.

The previously approved ICR expired on December 31, 2015; however, the expiration date is extended monthly (currently, to March 31, 2016) while OMB conducts the review and approval process for the revision. OMB has received and is considering all written comments regarding the ICR revision that were submitted by February 8, 2016. It is noted in the supporting statement from the OFCCP that there are currently 82 contractors with a FAAP agreement, covering more than 1,900 functional units. Based on trends in prior years, the OFCCP has estimated that there are approximately 10 new requests each year for FAAP agreements. Until OMB completes its review of the FAAP ICR, contractors are encouraged to continue communicating with the OFCCP regarding any updates, modifications, or renewals made to active FAAP agreements.

By Bryce Hansell, HR Analyst and Keli Wilson, Principal Consultant at DCI Consulting Group 

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