The Office of Federal Contract Compliance Programs (OFCCP) has published a revised directive regarding the use of Functional Affirmative Action Plans (FAAPs). A FAAP requires specific OFCCP approval and is a departure from the typical “establishment-based” AAP structure for multi-establishment facilities, using an AAP structure that is more in line with the business functions or business units of the contractor. A functional or business unit refers to a component within an organization that operates autonomously in the ordinary course of the organization’s business. To be considered suitable for a FAAP, the functional or business unit must: 1) currently exist and operate autonomously; 2) include at least 50 employees; 3) have its own managing official; 4) have the ability to track and maintain its own personnel activity.