“What is an Affirmative Action Plan?”, “Does my company need an AAP?”, “How do we implement it?”, “What do I do if we get audited?”
These are all frequently asked questions I hear just about every week as the resident Affirmative Action Plan expert at Helios. Let me first preface by sharing that Affirmative Action Plans (AAP’s) are designed to satisfy the equal-employment opportunity/affirmative action responsibilities for minorities and women under Executive Order 11246, as amended; people with disabilities under section 503 of the 1973 Rehabilitation Act; and covered veterans under the Vietnam Era Veterans’ Readjustment Act of 1971.
Ok, now moving on to your more specific questions…
“What is an Affirmative Action Plan?”
In the simplest terms, AAP’s are a roadmap of an organization’s programs, policies, and procedures for ensuring equal opportunity in all aspects of employment including recruiting, hiring, training, promoting, and compensation. Affirmative actions include training programs, outreach efforts, and other positive steps to support recruitment and selection goals.
“Does my company need an AAP?”
Federal contractors and subcontractors with 50 employees and $50,000 in government contracts are required to develop, implement and maintain AAP’s while providing goods and services to the federal government.
“How do I implement an AAP?”
AAP’s consist of a narrative and a statistical component. The narrative is a detailed description of the practices of an organization in support of the good faith efforts to protect women, minorities, veterans and disabled employees from discrimination in hiring practices both intentional and impactful. The statistical component includes the following analyses:
- Workforce Analysis – listing of job titles in the organization classified into organizational units or work groups
- Job Group Analysis – listing of each job title in the organization in terms of job groups and identifies the number of female and minority incumbents in each job group
- Availability Analysis – determines the availability of women and minorities by considering a reasonable recruitment area and promotions possible in the organization
- Utilization Analysis – compares incumbent women and minorities with available women and minorities and identifies areas of underutilization
- Adverse Impact Analysis – determines the statistical indication of adverse (disparate) impact against a protected class and analyzes the HR flow in all aspects of employee selection, promotions and terminations
Placement goals must be set when the percentage of minorities or women in a job group is less than reasonably expected given their availability percentage in that job group. Placement goals equal the availability percentage and serve as targets that organizations can meet through good-faith efforts and action-oriented programs.
“What happens if I get audited?”
The Office of Federal Contract Compliance (OFCCP) enforces affirmative action and equal employment opportunity of federal contractors. If your company receives a notice of audit, you will have 30 days to respond to the audit request and will be required to provide a copy of the current AAP as well as provide documentation supporting the good faith efforts of providing and maintaining a discrimination free recruitment and selection process.
Have more questions?
Helios can help you along every step of the way from designing, implementing and audit response consulting for Affirmative Action Plans. Feel free to give us a call at 703-860-3882 if you need additional help. Here are a few other sites that serve as great resources as well: Sample Affirmative Action Plan and OFCCP Affirmative Action Fact Sheet.