Did you happen to hear the news story last week about the young man who was applying for a job with Staples via the web and was shocked to have received a questionnaire offering him the opportunity to disclose if he is an individual with a disability? As a Human Resource professional with a background in government contracting compliance I knew exactly why the opportunity to disclose was given to the applicant, and quite frankly I was not at all surprised the applicant was not aware of the new requirements in place for government contractors. But I began to wonder how many of the employees working for government contractors are unaware of these new regulations.

Just this past week the new rules by the Office of Federal Contracting Compliance Programs (OFCCP) went into effect in an effort to strengthen the recruitment efforts by government contractors to hire more veterans and persons with a disability. As a government contractor compliance SME, we hear a great deal about “good faith efforts” when it comes to recruiting but as a government contractor how do you exhibit the “good faith efforts” to the OFCCP if your company has been selected for an Affirmative Action Plan (AAP) audit?

As a Practice Leader here at Helios I have an opportunity to work with many government contractors grappling with the record-keeping requirements of maintaining their Affirmative Action Plans. Commonly referred to as an AAP, it's a program that outlines the equal employment opportunities and advancement, specifically for businesses with federal contracts or funding. As a government contractor, whether you are a prime or a subcontractor, your company must demonstrate the application of good faith efforts to increase the pool of qualified minority, female, veteran and disabled candidates when recruiting for open positions. The AAP plan is subject to scrutiny by the Office of Federal Contracting Compliance Programs (OFCCP) if your organization is selected for a compliance audit.

"What is an Affirmative Action Plan?”, “Does my company need an AAP?”, “How do we implement it?”, “What do I do if we get audited?” These are all frequently asked questions I hear just about every week as the resident Affirmative Action Plan expert at Helios. Let me first preface by sharing that Affirmative Action Plans (AAP’s) are designed to satisfy the equal-employment opportunity/affirmative action responsibilities for minorities and women under Executive Order 11246, as amended; people with disabilities under section 503 of the 1973 Rehabilitation Act; and covered veterans under the Vietnam Era Veterans’ Readjustment Act of 1971.