September 06, 2019 | By NACE Staff
TAGS: legal issues, nace insights, OFCCP
Spotlight for Recruiting Professionals
The Office of Federal Contract Compliance Programs (OFCCP) recently released a set of FAQs that address affirmative action programs (AAPs) that cover a campus-like environment. The FAQs were developed to help contractors with campus-like settings determine whether to maintain one or multiple AAPs to cover the employees on the campus.
As the agency notes, under its regulations, a contractor must maintain an AAP for each of its establishments and include all of its employees in an AAP. Generally, OFCCP considers an establishment to be a physical location, such as a factory or office.
“However,” it continues, “some contractors with campus-like settings may have multiple buildings that constitute an establishment for purposes of developing and maintaining their AAPs. These types of contractors could include educational institutions, hospitals, and information technology companies, among others.”