To be clear, the OFCCP is still open for business. The agency is still auditing and still expects contractors to complete, implement, and maintain their AAPs.
BCGi has been getting several questions that appear to be prompted by incomplete and potentially misleading headlines regarding the OFCCP’s coronavirus relief exemption.
The “exemption” here only applies to federal contracts related to coronavirus relief, as determined by the contracting agency. Entering into such a contract does not exempt the organization from existing affirmative action obligations.
If a contractor holds no other qualifying federal contracts, they will not be required to prepare AAPs and will not be audited because they enter into a contract related to coronavirus relief. Existing federal contractors are not affected by this exemption.
If you have questions, please do not hesitate to reach out to us at BCGi@biddle.com.