OFCCP Issues Directive 305 Outlining Process for Functional Affirmative Action Plans (FAAPs)

By | December 17, 2012

On December 17, 2012, the Office of Federal Contract Compliance Programs (OFCCP) issued Directive 305 which outlines the procedures for requesting, modifying, updating, renewing, and terminating Functional Affirmative Action Plans (FAAPs) Agreements.

Directive 305 supersedes Directive 296, which was issued June 14, 2011. The new directive can be found at: http://www.dol.gov/ofccp/regs/compliance/directives/dir305.pdf.

Both directives include provisions regarding the submission of data from contractors.  The primary reason for the new directive was that this constitutes an information collection request (ICR) under the Paperwork Reduction Act, which requires the approval of the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA), which was granted on December 11, 2012.

While Directive 305 is very similar to Directive 296, there are several differences, including in the documents required to be submitted prior to the FAAP conference.  Contractors are no longer required to submit VETS 100/100A reports or a workforce analysis.  The total number of employees within each business or functional unit is now required to be submitted by location as opposed to by race and gender.  Finally, contractors are no longer required to submit the identification of major job groups within the proposal functional or business units, job titles within the job groups, the current number of employees by race and gender in each job group, and the relevant recruitment area for each job group.

Please contact us by calling (732) 446-2529 or sending us an e-mail at glennbarlett@gbcs.net if you are interested in additional information regarding Functional AAPs.