News & Announcements
OFCCP Releases More Compliance Assistance Resources
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.