I Just Finished My Affirmative

Action Plan: Now What?

Strategies and Techniques for

Implementing Your AAP

Objective

The purpose of this webinar is to provide you with

specific strategies and techniques you can

incorporate into your human resources and

affirmative action efforts, and processes that will

allow you to actually put your affirmative action

plan into place.

Cindy Karrow, SPHR

“Discrimination is preventable when employers have

certain processes in place and see to it that they are

followed, that’s why it’s so important for federal

contractors to implement their affirmative action

programs, keep accurate employment records and

commit to ending barriers to fair employment. A

proactive strategy is the best way to guarantee that

all workers have an equal opportunity to succeed in

the workplace. Plus, it’s the law.”

– OFCCP Director Patricia A. Shiu

AAP Implementation

Affirmative action implementation includes several components:

• Action Oriented Programs and Good Faith Efforts

• Communication

• Monitoring

• Documentation

• Workforce Planning

ACTION ORIENTED PROGRAMS

AND GOOD FAITH EFFORTS

Action Oriented Programs

Develop Action Oriented Programs to address

problem areas and help achieve goals

Develop partnerships and relationships with

recruitment sources that can provide qualified

candidates for open positions including women,

minorities, Veterans, and the disabled

Devote time, money, and other resources to efforts

which are effective and produce measurable results

Action Oriented Programs

Review job descriptions to ensure they reflect job

requirements

Examine the selection process to check for bias in

decision making

Train recruiters and managers on nondiscriminatory

screening, interviewing techniques, and

recordkeeping requirements

Action Oriented Programs

Implement new hire orientation program to include

review of EEO, AA, and harassment policies

Expressly prohibit discrimination and harassment

Review your communications (printed internal and

external publications, consumer advertisement,

website) to ensure minorities, women, and individuals

with disabilities are featured

Action Oriented Programs

Conduct periodic audits to ensure facilities are not

segregated, neither in policy nor use

Ensure minorities, women, Veterans, and individuals

with disabilities are provided a full opportunity and

encouraged to participate in all company sponsored

educational, training, recreational, and social activities

Analyze conditions of employment to ensure no

unlawful distinctions in employment opportunities

and/or fringe benefits exist

Action Oriented Programs

Make good faith efforts to carry out these programs

Keep accurate records of these activities including

the analysis of their effectiveness

Questions on Action Programs

COMMUNICATION

Communication

It is the responsibility of the Affirmative Action Officer to

communicate to all managers, supervisors, and HR staff

involved in recruiting, the placement goals for the year.

Communication

Identify Target Audience

• Executives

• Human Resources

• Managers

Timing & Frequency

• Annually

• Bi-annually

• Quarterly

• Ongoing

Customized Message

• Role of audience

• Purpose of message

Communication

1. Highlight reasons the organization creates AAPs

Carrot Stick

Summarize benefits to the organization

-existing contracts

Recent EEOC and OFCCP settlements

Review OFCCP results from prior fiscal year

Communication

2. Review plan reports

Present and explain annual or update reports,

statistics, and goals

Communicate success

3. Communicate action plan

Potential problem areas

Associated action oriented programs

Communication

Conduct regular, ongoing affirmative action meetings

to communicate the annual plan, update plan,

implementation, as well as ongoing progress reports

on action orientated programs and results

Provide training in EEO/AA to management and

recruiters

Communication

Communicate to employees the company’s commitment

to Equal Employment and Affirmative Action:

Communicate HR policies including EEO and anti-

harassment

Post affirmative action exhibits and ensure

required posters are displayed at each location

Questions on Communications

MONITORING

Monitoring

Identify milestone goals throughout the year to evaluate progress towards annual goals

Monitor placement of minorities and women monthly or quarterly to allow changes to recruitment strategies as needed

Job groups without goals should maintain a placement rate at or above availability

Review adverse impact on personnel actions throughout the year

Monitor compensation – starting pay and compensation changes

Monitoring

Periodically conduct a self audit of the applicant

process to uncover deficiencies such as:

Applications and/or resumes discarded if didn’t

meet definition of an applicant

Recruitment folders maintained but with

superfluous information in them

Self-ID forms attached to applications

Monitoring - deficiencies

Inconsistent or no interview questions

Inconsistent or no minimum qualification or criteria for

reviewing applicants

Notes written directly on resumes or applications

Questions on Monitoring

DOCUMENTATION

Documentation

As it relates to hiring:

Copies of all employment advertisements and

postings, including those posted with the state

employment agencies

Interaction with employment recruiting and outreach

resources

Records identifying job seekers contacted regarding

their interest in a particular position

Documentation

Employment tests and results, if used for selection

Specific records of searches on résumé databases

Position descriptions and worker specifications are

available to all members of management involved in

the recruiting, screening, selection, and promotion

process

Documentation

As it relates to employment:

All employment records, including applications,

interview notes, and performance evaluations

Accommodations made or denied for employees and

applicants

Copies of EEO-1, VETS-100, and VETS-100A reports

Documentation

As it relates to your affirmative action plan:

Meeting minutes showing affirmative action on the agenda

Attendance at meetings and affirmative action program activities

Materials which document activities and efforts

Information on previous OFCCP audits

Prior year’s affirmative action plan

Copy of purchase order

Documentation

Policies and procedures which explain your applicant

process, selection, employment physicals, required

tests, job descriptions, job specifications, job postings,

transfers, promotions, seniority systems, and

mentor/apprenticeship/internship programs

Formal EEO Policy Statement

Anti-harassment policy and complaint procedure

Questions on Documentation

WORKFORCE PLANNING

Workforce Planning: Selection

Review and update the job analysis:

job duties and requirements

appropriate salary level

basic qualifications

interview questions

selection tests/instruments

applicant appraisal/performance evaluation forms

Workforce Planning: Selection

Write job descriptions to include:

Job title

Status

Salary information

Reporting relationships

Job summary

Job tasks & responsibilities

Job qualifications

Physical demands

Working conditions

ADA and/or OSHA requirements

Workforce Planning: Selection

Develop an applicant policy which addresses:

equal employment opportunity

solicited vs. unsolicited submissions

data management techniques

a prescribed process of submission

when to solicit race and gender

how to handle internal applicants

utilization of search firms and other third party vendors

Workforce Planning: Selection

Consider applicant procedures which:

utilize requisition numbers

establish meaningful disposition codes

route all submissions to your website or other

electronic avenue

use a reliable electronic applicant tracking tool

ensure everyone involved in the selection process is

trained on policies and procedures

include self-audits to ensure compliance

perform adverse impact analysis on each step in the

applicant process

Workforce Planning: Selection

Develop:

external recruitment strategies for minorities, women,

Veterans, and individuals with disabilities

internal strategies to train and promote minorities,

women, Veterans, and individuals with disabilities

Workforce Planning: Selection

Consider various external sources:

Newspapers

Trade Associations

Trade Journals

Civic or Community Groups

Public Agencies

Private Agencies

Minority Organizations

Women’s Groups

Organizations for the disabled

Veterans Groups

Secondary Schools

Technical Schools

Community Colleges, Colleges and Universities

Mentor/Apprentice/Intern Programs

Workforce Planning: Selection

All job postings should include:

job title and requisition number

location and salary information

job duties and responsibilities

basic qualifications

education

experience

knowledge and skills

instructions on how to apply

equal employment language

Workforce Planning: Selection

You must:

post all jobs with the state employment agency or

One Stop Career Center

maintain posting documentation

maintain records of response

ensure employment tests are valid, job related, and

do not have an adverse impact on applicants

Workforce Planning: Selection

Analyze effectiveness:

verify sources are providing qualified candidates

ensure diversity of recruitment sources

develop and maintain relationships with the sources

Workforce Planning: Retain

To retain valuable employees, consider:

conducting compensation analysis to ensure internal

equity

developing an effective performance management

system

conducting regular performance reviews

developing career paths

providing career counseling

Workforce Planning: Promote

To create opportunities to promote qualified

employees, consider:

providing training to ensure an internal pool of well

qualified applicants

tuition reimbursement programs

utilizing mentoring programs

developing cross-training programs

Questions on Workforce Planning

AAP Implementation Recap

Affirmative action implementation includes several components:

• Action Oriented Programs and Good Faith Efforts

• Communication

• Monitoring

• Documentation

• Workforce Planning

Thank You!

Questions:

webinarquestions@berkshireassociates.com

Compliance Support:

800-882-8904

This program, ORG-PROGRAM- 122091,has been approved for 1 (General) recertification credit hours toward PHR, SPHR and GPHR, recertification through the HR Certification Institute. Please be sure to note the program ID

number on your recertification application form.