Dear Harold,
How does OFCCP handle pre-award compliance reviews when a contractor has a Functional Affirmative Action Program (FAAP) Agreement?
Harold:
In response to your question, the first matter to point out is that the OFCCP Directives on the FAAP Procedures are silent on the issue of Pre-Award Compliance Reviews. Therefore, the process would follow normal pre-award clearance procedures: even if the place of performance that is being considered for the award is covered under a FAAP, the pre-award procedures would be initiated at that location only.
In other words, if a review would be scheduled for a contractor's establishment which was not under a FAAP, then this same procedure would occur for an establishment covered by a FAAP. OFCCP National Office Staff provided confirmation of this approach.
Harold M. Busch
Vice President, Government Relations
DCI Consulting Group, Inc.
