Well, it’s that time of year again! Time for the annual update of the Affirmative Action Plan (AAP)! You made a point to include this project in the business plan, and to schedule the resources needed to get it done, on time, this year. But as you look around the organization, you see several competing business interests and priorities that may derail the best laid plans.

You could possibly defer this project into the next quarter. However, you are not confident that all the resources you will need will be available even then. Maybe this is the year to consider outsourcing this project so that you can stay on track with achieving your business objectives. There are a variety of factors that bear on the decision on whether to engage an outside consultant to manage the AAP development project.


Ideally, the Affirmative Action Plan should be ready to go on or near the beginning date of the AAP year (e.g., January 1 for a calendar year AAP). Does the person or team with responsibility for the AAP project have time now to work on this? Depending on the size of the company and the number of AAP establishments, the project may take some time (several weeks!) to complete, especially if it is being done on a piecemeal basis, in between other projects. Does anyone have time now or at a later date to devote to this work?

Time is of the essence! If the project is delayed, how timely will the AAP results be? How much time will be remaining in the AAP year to work on addressing goals and other potential problem areas identified in the analysis?

Getting the Plan done is important, but it is just the beginning. The sooner you get it done, the more time you will have to focus your efforts on implementing the AAP.


Gathering and clean-up of the data needed for AAPs (current year workforce, prior year personnel activities, including applicant files) can be an arduous and time-consuming process. But it is the most important part of the AAP development process. If the data is not reliable, then the results of the AAP analysis are not meaningful. Someone in the company will initially be responsible for gathering the data. However, an AAP consultant would have the time and expertise to focus on data management of the files to produce clean files for AAP analysis.

Knowledge and Expertise

Do you have anyone on your staff who has experience in developing AAPs? An experienced AAP consultant would be familiar with other companies, large and small, in your industry, and use that knowledge in designing an effective affirmative action program for your company. Rather than take a cookie-cutter approach, they could offer practical solutions that are specific to your AAP program needs.

Using an outside consultant would also provide for an independent review of your AAP, and your employment policies and practices to ensure compliance with the affirmative action regulatory requirements of the Office of Federal Contract Compliance Programs (OFCCP).


Outsourcing the development of AAPs can be a cost-effective solution for many companies. When compared to the cost for the employee time and other expenses needed to have the AAPs developed internally, the fee for outsourcing the AAP project can be quite reasonable.

An added benefit of outsourcing is that it frees up more time for you to spend on the implementation of the AAP program.

Compliance Status

Are you ready for an OFCCP Compliance Evaluation (audit)? In addition to developing AAPs, outside AAP consultants often are involved in providing support to companies undergoing OFCCP audits. As a result, they are current on changes in the OFCCP’s AAP regulations, and have insight on the agency’s enforcement strategies and practices.

This provides two special benefits for you:

  • Your AAP will be fully compliant with all of the current regulatory requirements, and be “audit-ready”.
  • In the event you are selected for an OFCCP audit, your AAP consultant will be ready to provide audit support because they are already intimately familiar with your AAP program.


Given the potential programmatic and cost benefits, outsourcing the AAP development program certainly is worthy of consideration. If it allows you to be able to do more with less by focusing your resources on implementing your company’s affirmative action and diversity and inclusion strategy, then maybe it is an idea whose time has come.

Gain Buy-In to Outsource Your AAP

When it comes to HR and budgets, we understand the need to justify expenses to management. Download this printable graphic to share with your team so you can articulate the benefits of using a third-party source. As always, Taapestry is available to assist and happy to discuss their process and benefits of working with our experienced team. Learn more about Taapestry and Affirmative Action Development and services by visiting https://directemployers.org/taapestry. 

Tony Perkins
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