April 14th, 2022
9:00 AM PT
Join the leaders in Affirmative Action Planning as they discuss the impact of the OFCCP Contractor Portal. Covered federal contractors and subcontractors must use this portal to certify, on an annual basis, whether they have developed and maintained an affirmative action program for each establishment with 50 or more employees.
On March 31, 2022, contractors will be able to utilize the certification feature in the portal to certify their AAP compliance. And, by June 30, 2022, existing contractors must certify whether they have developed and maintained an affirmative action program for each establishment and/or functional unit, as applicable.
Entities that are affiliated with a contractor or subcontractor (corporate parent, affiliate, or subsidiary) may incorrectly assume they do not need to certify. This is not necessarily the case. OFCCP applies a five factor test to determine whether these entities are considered “single entities” with the contractor or subcontractor, which could make them subject to the AAP requirement for all their establishments. This issue will likely come to a head now that OFCCP is requiring certification and relying on corporate parent EEO-1 data so companies should analyze this issue and determine how best to proceed.
Likewise, many contractors with multiple locations incorrectly assume that only the location with the government contract needs to certify. Not many contractors with multiple establishments realize that they will have to certify compliance for each and every location unless they have secured an approved Separate Facility Exemption Waiver from OFCCP.
Join us in this webinar as we walk you through the Single Entity Test and Separate Facility Exemption Waiver, and why it is important to consider these issues now before you certify.
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