In a step toward implementation of OFCCP’s Affirmative Action Program (“AAP”) Verification Initiative, the Office of Management and Budget (OMB) approved an Affirmative Action Program Verification Interface (AAP-VI) that OFCCP developed for federal contractors to submit AAPs.

Although the verification program has not yet launched, and details are scarce, the OFCCP already has an AAP-VI website which promises the program is “Coming Soon” and explains that “Affirmative Action Program Verification Interface (AAP-VI) is a secure web based interface created to improve communication and the transfer of Affirmative Action Program data, between Federal Contractors and the Office of Federal Contract Compliance Programs.”

As previously reported, in furtherance of Directive 2018-07, on September 14, 2020, OFCCP published a notice soliciting comments concerning its proposal to obtain approval from the OMB to implement the AAP-VI. The notice stated the AAP-VI would be used to assist with a yet-to-be-established AAP online certification process for federal contractors and provide a secure method for federal contractors to submit AAPs electronically to OFCCP when they are scheduled for a compliance evaluation.

Presently, federal contractors are only required to submit their AAPs via mail or email and are not required to certify annually to the OFCCP that their AAPs are compliant. According to the OFCCP AAP-VI Federal Contractor User Guide, “[t]he AAP-VI system will be the primary source for entering, tracking and submitting [] Affirmative Action Programs for review by OFCCP. AAP-VI will provide federal contractors a system to submit their Programs in a more efficient manner and provide visibility and reporting capabilities of the data submitted by the Programs.”

We are still awaiting further details from the OFCCP, we will continue to closely monitor and report on new developments. In the meantime, additional information can be found in OFCCP’s AAP-VI Administrative Guide and OFCCP’s AAP-VI Federal Contractor User Guide. Further, contractors should be getting ready for the launch of the verification interface by making sure their AAPs are prepared and ready for “prime time,” including ensuring they meet all of OFCCP’s requirements.