Ask Harold: Pre-Award Compliance Reviews & FAAP Agreements

Dear Harold,

How does OFCCP handle pre-award compliance reviews when a contractor has a Functional Affirmative Action Program (FAAP) Agreement?


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.

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