If a recipient already has an Affirmative Action Plan (AAP) in effect, can it submit the AAP to the Office for Civil Rights (OCR) instead of the EEOP Short Form?
No. An EEOP and an Affirmative Action Plan (AAP) are not the same. Extracting from the AAP relevant statistical data and employment policies, a recipient may use its AAP as a resource in preparing the EEOP Short Form. However, the OCR will not accept a previously prepared AAP as a substitute for the EEOP Short Form.