OFCCP has recently published several new Directives with important information for employers who are federal contractors and subcontractors.
One of these, Directive 2018-07, is focused on employers who are either late with yearly AAP update(s), or who fail to prepare them at all.
According to this directive, OFCCP will no longer grant extensions for data submission to employers who receive audit notices. This will have significant impact on employers whose AAPs are not complete when a Compliance Review notice arrives.
According to the directive, OFCCP also is considering requiring an annual renewal certification.
Now is a good time to resolve to prepare 2019 AAPs on schedule. HR Specialties strongly advocates timely AAP update. Late plans can have consequences, such as failing to identify adverse impact early enough to address the cause.
The complete Directive 2018-07 can be found here: https://www.dol.gov/ofccp/regs/compliance/directives/Dir2018-07-ESQA508c.pdf