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How to Manage an Affirmative Action Plan

Author: Linda Segall, Segall Enterprises

NOTE: On January 21, 2025, President Trump signed Executive Order (EO) 14173Ending Illegal Discrimination and Restoring Merit-Based Opportunity. The EO revokes several EOs from previous administrations that established and expanded affirmative action requirements for certain federal contractors. The Office of Federal Contract Compliance Programs (OFCCP), which oversees federal contractors, is directed to immediately cease holding federal contractors responsible for complying with affirmative action requirements based on race, color, sex, sexual orientation, religion or national origin. Federal contractors may continue to comply with revoked affirmative action requirements for 90 days from the date of the order.

Affirmative action requirements under the Vietnam Era Veterans Readjustment Act of 1974 (VEVRAA) and Section 503 of the Rehabilitation Act (pertaining to disability) remain in effect.

This resource reflects affirmative action requirements as they existed prior to January 21, 2025. Updates will be forthcoming.

One of the requirements of an affirmative action plan (AAP) is to indicate how the plan will be audited. It is not enough, however, merely to outline audit procedures. The intent of the audit section is to develop accountability within the employer's organization to achieve the AAP's goals and to eliminate the underutilization of females and minorities within all affected job groups. In other words, the affirmative action program must be managed.

The following steps help ensure the effective management of the AAP: