Redstone Government Consulting Blog | Office of Federal Contract Compliance Programs (2)

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

In the previous blog of this series, we focused on the requirements of federal government contractors (prime and subcontractors) who meet the basic threshold requirements (specific dollar thresholds and fewer than 50 employees). As we progress in this series on OFCCP and Affirmative Action Requirements, we begin to dive into OFCCP’s expectations of a contractor’s Affirmative Action Program (AAP). As a reminder, contractors are required to have an AAP when meeting the dollar thresholds mentioned above and have an employee count of 50 or more.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

The last blog in this series focused on who (what) OFCCP is, what they require of contractors of various sizes and why compliance is important. Now we want to provide a bit more clarity as to what these requirements are and later in the series, how those requirements impact your processes and policies.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

As mentioned in a previous blog, OFCCP’s Contractor Portal, we are kicking off a blog series related to OFCCP and Affirmative Action requirements for contractors of all sizes. We begin this series by laying the groundwork of who (or what) OFCCP is and what affirmative action is. This series will focus on supply and service contractors; however, construction contractors may also find it helpful. Regardless of the type of contractor, our HR Team is available to assist with all of your OFCCP compliance and Affirmative Action Program (AAP) needs.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

What is it?

The Office of Federal Contract Compliance Programs (OFCCP) Affirmative Action Program Verification Interface (AAP-VI), or “Contractor Portal” is a new platform to be used by covered government contractors (prime and subcontractors) to:

• Annually certify that they are complying with the requirement to develop and maintain annual Affirmative Action Plans (AAP).
• Upload Affirmative Action Plans and other requested materials during an OFCCP compliance evaluation.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

The Office of Federal Contract Compliance Programs (OFCCP) has announced that their new Contractor Portal will be going live in 2022. The Portal will require contractors to certify, on an annual basis, whether they have developed and maintained an affirmative action program for each establishment and/or functional unit, as applicable.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

You’re probably not feeling quite like THIS about training, but we do want to remind you of a few topics that you, as a federal government contractor, need to address with your workforce on a fairly regular basis. We can’t hit them all, but this is a list of those that should be on the radar of your Human Resources staff and are relevant to most contractors.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

On September 22, 2020, President Trump signed an Executive Order (EO) seeking to end what is characterized in the Order as "training sessions based on race and sex stereotyping and scapegoating" in the federal workforce, the Uniformed Services, and among federal contractors. The EO provides that it will be the policy of the United States "not to promote race or sex stereotyping or scapegoating" in the federal workforce and the Uniformed Services, and not to let grant funds to be used for these purposes.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

Under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), federal contractors and subcontractors with contracts valued at $150,000 or more are required to file an annual VETS-4212 report disclosing the number of veterans in their workforce. All contractors and subcontractors who meet the contract threshold amount are required to file a VETS-4212 report, regardless of their total number of employees. Data reported through form VETS-4212 is used by the Office of Federal Contract Compliance Programs (OFCCP) to conduct compliance evaluations. The annual filing period for form VETS-4212 is August 1 through September 30. The 2020 filing deadline is September 30, 2020.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

If your company is subject to EEO-1 reporting or if you’re a contractor, Self ID forms are old news but as OMB has approved a new Voluntary Self-ID of Disability form, now is a good time for a refresher.

This article is under review as a result of EO 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, signed by President Trump on January 21, 2025. As we await further information from OFCCP and the courts, please reference this article for current status and action items.

On February 22^nd, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) announced that it will now post its Corporate Scheduling Announcement List (CSAL) in its Freedom of Information Act (FOIA) library instead of sending advanced notifications to individual establishments. The next CSAL is expected to be released in early to mid-March.