By: Deborah Fashole-Luke and Rosemary Cox
This year is the inaugural year of the Office of Federal Contractor Program’s (OFCCP) Contractor Portal. Throughout a months-long registration and certification period, federal contractors and subcontractors had to navigate this new system to document their compliance with affirmative action regulations by June 30th, 2022. Predictably, this new portal and process created a number of challenges and issues that contractors and subcontractors had to resolve, which we detailed in a prior blog.
As part of the registration process, the Portal used EEO-1 company numbers to help match contractor registrations with data held in in a federal database. Universities and educational institutions, however, do not file EEO-1 reports. During the registration period, these contractors were instructed to register using their Integrated Post Secondary Education Data System (IPEDS) unit number. Universities and higher education institutions with multiple affirmative action plans (AAPs) were particularly impacted by this, because they were unable to file multiple AAPs under the same IPEDs unit number.
In response to this issue, OFCCP updated the Federal Contractor Portal User Guide with additional information for universities and higher education institutions:
- Educational Institutions will first have to create an account on the Portal and agree to the Portal’s terms of behavior.
- The Portal will include the following screening question for universities and higher education institutions: “Are you accessing the system as a representative of an educational institution?” Representatives of universities and higher education institutions should answer “Yes” to advance to the next screen.
- A “User Authorization” page will then be displayed where the university or higher education institution’s Employer Identification Number (EIN) and IPEDS unit number will be needed to continue.
- A “Create Parent Company” page will follow. Users must then enter the university or higher education institution’s parent information (including the institution’s name and parent name, IPEDS ID, Data Universal Numbering System (DUNS) number, and North American Industry Classification System (NAICS) number, and EIN)
- Once the Parent Company information is completed and saved, the Portal Dashboard will be displayed. From there, functional/business units or establishments can be added under the same parent institution by clicking on “My Company” and then “+ Add New Establishment or Functional/Business Unit”.
- The “Manage Establishments or Functional/Business Units” option can then be used to view or edit any saved information for each individual functional/business unit or establishment for the Educational Institution.
Educational Institutions that already have an active login will not need to go through this registration process again.