The Office of Federal Contract Compliance Programs (“OFCCP”) has been releasing numerous compliance assistance resources to help employers better understand the law.  Here are some of the latest resources:

• FAQs on Developing Establishment-Based AAPs for Campus-Like Settings: Contractors with “campus-like settings” could include educational institutions, hospitals, and information technology companies.  These FAQs provide guidance on whether one or multiple affirmative action programs (“AAPs”) should be maintained for a multi-building establishment.  Generally, employers may combine multiple buildings into a single establishment AAP if the operations across those buildings are interconnected.
• The Student Worker Directive: Directive 2019-05 provides guidance on whether academic institutions need to include student workers in their AAPs and the support data submitted to OFCCP during a compliance evaluation.  The directive indicates that OFCCP will exercise its enforcement discretion by limiting its compliance evaluations of educational institutions to non-student employees, while still accepting complaints alleging employment discrimination by and on behalf of student workers who qualify as employees under the relevant legal tests.  See also the recently-released FAQs on Student Workers.  OFCCP also plans to release a technical assistance guide for educational institutions soon.
• The HBCU Webpage: The OFCCP, in partnership with the White House Initiative on Historically Black Colleges and Universities (“HBCU”), has created a website to provide federal contractors with resources to help them increase the representation of minorities and females in career-level jobs.