On June 28, 2011, the Office of Federal Contract Compliance Programs (OFCCP) released a new directive specifically authorizing the use of Functional Affirmative Action Programs (FAAPs) and detailing applicable procedures.  While most covered contractors prepare affirmative action plans based on establishment, some contractors (typically, very large, multi-establishment companies) conclude that an affirmative action plans based on function or unit (such as sales, or R&D), which cut across establishments, more appropriately analyze the workforce.