Affirmative Action Programs (AAPs)

Giving You Confidence from Start to Finish

At Gaucher Associates, our focus is the design, development and defense of Affirmative Action Programs (AAPs). We have written thousands of AAPs for our clients, each tailored specifically to their business needs and goals.

We do not simply “dump” your data into a software program that generates your AAP(s). We review and organize each client’s data to ensure completeness and consistency. Then we customize each AAP to fit the client’s workforce at each location, its industry, and its management structure.

We proactively assist our clients in addressing any potential concerns in order to reduce vulnerability in an audit. This includes recruiting and candidate selection processes, applicant tracking systems and practices, compensation equity, and overall AAP documentation and recordkeeping.

Our staff has successfully defended hundreds of client AAPs in all types of Office of Federal Contract Compliance Programs (OFCCP) audits, representing our clients through every step of the audit process. 

And we are always available to answer clients’ questions, to provide up-to-the-minute advice on any AAP-related issue and to provide best practice solutions to any AA/EEO problems you may encounter.

Effective Affirmative Action Solutions

Gaucher Associates customizes Affirmative Action Programs to meet your organization’s specific needs with personalized attention to detail. Our services include:

  • Strategic design and development of fully compliant Affirmative Action Programs that meet the most current OFCCP regulations.
  • Analysis, advice, and assistance with critical compliance areas including compensation practices; hiring, promotion, and termination impact ratios; outreach and recruitment; and maximizing utility of an applicant tracking system.
  • Delivery of an Executive Summary highlighting potential audit red flags and identifying recommended corrective actions.
  • Full OFCCP Audit Representation for our clients, from receipt of the audit scheduling letter through audit closure and post-audit reporting.
  • Evaluation of the risks and benefits of the Functional Affirmative Action Program (FAAP) structure for large multi-establishment clients and preparation and filing of FAAP requests when appropriate.

Advantages of Working with Gaucher Associates

Whatever your question, chances are we’ve heard it before. We have been providing superior client services since 1994. Our consultants have more than 125 years of combined AAP development experience as well as educations and backgrounds in many different industries, including engineering & technology, insurance & finance, healthcare, government and law.  

You know your consultants are keeping up to date in an ever-changing regulatory environment.

You know you have a compliant, defensible Affirmative Action Program prepared by experienced and knowledgeable professionals.

You know that your program was tailored specifically for your organization and includes customized compliance recommendations.

You never have to worry if your company is selected for an audit.

And you know that Gaucher Associates will be there right by your side throughout the audit process.

How We Work

You will be assigned an experienced team member specifically chosen to meet your business needs and any relevant industry or regional considerations. We have team members in key locations across the country available to coordinate with you on your timeline.

Before we even begin developing your program, we review your data for anomalies and inconsistencies and work with you to answer any questions. We never just “dump in” the data.

Once your Affirmative Action Program (AAP) program is complete, we will deliver it along with an Executive Summary highlighting our findings, pointing out any problem areas and suggested corrective action(s), and providing advice on specific implementation strategies.

During our relationship, your dedicated consultant and the rest of our team is available for free telephone consultations on any aspect of your program or its implementation.

We seek to ensure that our clients are kept informed of any regulatory changes taking place – even before they happen – so we can work together to plan effectively for the future.

We provide comprehensive representation during an audit, from receipt of an audit notice through final closure. When you receive an audit letter we immediately draft a Notice of Representation for you to send to the OFCCP telling them that we are your representative and that all communications should be directed to us. This allows us to receive and respond to all OFCCP communications and lets you focus on your business. It further ensures that OFCCP requests are appropriate and receive the correct responses.


At Gaucher Associates, we provide fixed fee pricing based primarily on the size of your workforce and that of each individual establishment AAP so you won’t have any surprises.

Our Affirmative Action Programs are written specifically to meet your organization’s needs and include customized recommendations. We go beyond “just having a program” and assist our clients in improving their business practices to ensure compliance and long-term efficiency. We get to know your organization and data thoroughly. So much so, that many of our long-term clients have said to our consultants: “You know our data better than I do.”

We are always available to give you fast, courteous service from one of our senior staff members, ensuring that your program(s) will be completed properly and delivered on time.

free, confidential consultation

Find a time that fits your schedule or call us at 508-230-7001.