by Fred Satterwhite, Principal Consultant, DCI Consulting Group
OFCCP's new Functional Affirmative Action Program (FAAP) approval process- introduced with much fanfare by the agency in June, 2011- was approved by the Office of Management and Budget's (OMB) Office of Information and Regulatory Affairs (OIRA) on December 11, 2012. The information collection request was submitted to OIRA on October 11, 2012.
OFCCP had to put the official implementation of the new FAAP program on hold earlier this year because the required submission of information by a contractor during the early stages of the application for a FAAP agreement under the new program constituted an information collection request (ICR) under the Paperwork Reduction Act. Any ICR intended to apply to 10 or more recipients (in this case, federal contractors) must be approved by OIRA prior to use.
The approved ICR may now be used by the agency, and does not need to be approved again by OIRA until the end of 2015.
