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As a Federal Contractor, are you aware of the Affirmative Action Plan (AAP) Requirements by the OFCCP?


Are you a Federal Contractor?  If so, are your recruiters aware of the Federal Contractor AAP requirements to use the local State Employment Agency for job openings? Are they networking with veteran and disabled organizations to recruit and fulfill the 6.9% Veteran benchmark and 7% utilization goal for Disabled?  And, are they aware of your current year AAP goals for minorities and females as they recruit to fill those jobs with goals?  


As a reminder, if you have a single federal contract of $50,000 or more AND 50 employees, you must record and document your outreach efforts by completing an Outreach Assessment as required by the Office of Federal Contract Compliance Programs (OFCCP).  This documentation is important in case of an OFCCP audit.  Note: Outreach and recruitment was the second most cited violation by the OFCCP in 2015.   

There are 3 questions that need to be analyzed in your recruiting efforts and documentation:  (These records must be retained for 3 years.)

  1. Did the recruiting activity attract qualified applicants who are protected veterans and/or disabled?
  2. Did the recruiting activity result in the hiring of protected veterans and/or individuals with disabilities?
  3. Did the recruiting activity expand your outreach to protected veterans and/or individuals with disabilities in the community?

It is required that contractors create an AAP within 120 days after the award of the federal contract.  Federal Contractor AAP requirements state that the following information must be documented and updated annually: 

  1. Number of protected veteran applicants; 
  2. Total number of applicants for all jobs; 
  3. Total number of job openings and jobs filled; 
  4. Number of protected veterans hired; and
  5. Total number of applicants hired.


A special thanks to Karen Whiteside, President of KBW Associates, for sharing her expertise with us. Karen’s website is at, To receive her quarterly newsletter, contact her at or 760.771.6553.


Federal Contractors face a huge hurdle of regulations, including creating Affirmative Action Plans. Strategic HR, inc. knows that keeping abreast of legal compliance issues are important and can be a challenge, especially when the laws keep changing. We can help you stay compliant by offering resources to help you identify and mitigate compliance issues and by making sure you are informed of changes and reacting in a timely manner. Visit our Legal Compliance page to learn more about this helpful service.