Q. Besides a plan, what other Affirmative Action obligations do covered contractors have?
A. Because an affirmative action plan is intended to be, a true “plan” of action or Affirmative Action program, the contractor’s obligations and efforts are in large part set forth in the AAP itself. The affirmative action plan is designed to be actively implemented over the 12 months following the plan date. In addition to what is set forth in the plan, contractors also have significant data and record collection and retention requirements, posting, and reporting requirements. For instance, under VEVRAA and the JVA, contractors must, with limited exception; post all job openings with the state workforce agency as a key component to veterans outreach efforts.
Affirmative action contractors are also required to annually file an EEO-1 report. Beginning June 2015, contractors must file a VETS-4212 also. These typically must be filed by September 30 of each year. Information about these reports can be found at: http://www.eeoc.gov/employers/eeo1survey/index.cfm and http://www.dol.gov/vets/programs/fcp/main.htm.