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The Office of Federal Contract Compliance Program (OFCCP) recently revised Directive 2013-01 on Functional Affirmative Action Plans (FAAPs). The changes in this third revision to the Directive are relatively minor. The occasion, however, provides a good opportunity to review whether a FAAP is appropriate for your program, including what level of effort is involved in maintaining the Plans.
What is a FAAP?
What is a FAAP? OFCCP’s Frequently Asked Questions (FAQ) states that a FAAP “permits the development of a program organized around functional or business units [which are] not generally defined by physical location, but rather refers to a