In case you missed it, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has made complying with Affirmative Action Plan (AAP) filings a major focus area over the past several months.  A new portal has been created through which covered contractors are required to submit their plans for government review.  GSA sent out anInteract notice last week to Schedule contract holders stating that “supply and service contractors that employ 50 or more employees and hold a contract above a specific value are required to develop and maintain a written AAP under each of the authorities enforced by OFCCP.”  Further, “existing contractors who meet these requirements must register in OFCCP’s Contractor Portal and certify compliance for all qualifying establishments and functional/business.”  Companies that have fewer than 50 employees may be exempt from filing, though a recent incident we worked on made clear that not all OFCCP officials had gotten that piece of news.  Similarly, while the filing deadline via the portal had been June 30^th, OFCCP recently extended it “indefinitely”.  While the OFCCP website has a FAC feature to assist companies, some say that the information on it is not yet accurate.  Companies may want to contemplate working with outside experts familiar with AAP filing requirements.  It is important to point out that the requirement to file an AAP never went through a rule making process, so if you thought you missed that, there wasn’t anything for you to miss.  Some believe that this oversight may lead to a legal challenge but, for now, covered companies must submit AAP plans to OFCCP via the portal in a timely manner, even if “timely” is not currently defined with precision.