Data Validation and Audit Reconciliation · We do offer compensation courses at PeopleFluent. Make...
Transcript of Data Validation and Audit Reconciliation · We do offer compensation courses at PeopleFluent. Make...
Data Validation and Audit Reconciliation:
Rosemary Cox, SPHR, SHRM-CHP, SR-CAAP
Principal Business Consultant
Minimizing your AAP Risks and Preparing for an Audit
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Data is the new science. Big Data holds the answers.
Are you asking the right questions?
– Pat Gelsinger, EMC
Data are just summaries of thousands of stories – tell a few
of those stories to help make the data meaningful.
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It’s All About Telling Your Story
Agenda
• Reviewing your data BEFORE you receive an audit notice
• Data files
• Data inconsistencies
• Preparing for the audit submission
• Best practices
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It starts with your AAP at plan time
BEFORE you receive the audit notice
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When errors are not caught until an audit notice is received,
what happens?
Communication Requirements:
• Communicate plan results to Executives
• Communicate placement goals, benchmarks & utilization goals to management
• Train managers annually on EEO/AA responsibilities
If your original plans are not accurate and you find yourself re-doing the plan at
audit time:
Goals may change entirely - Managers would have been working on original goals. If interviewed
by auditor and goals are now different, violations may occur.
Adverse Impact changes and/or occurs with changes to data - If asked when adverse impact (AI)
was found and what was the outcome of the research, you will have to answer honestly and say at
audit time, which may cause a violation.
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Affirmative Action
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What data is needed?
• Employee File
• Static snapshot as of your AA plan date
• Hire File
• Information on anyone hired during preceding year
• Promotion File
• Information on anyone promoted during the preceding plan year – need promotion TO
and FROM information
• Transfer File
• Information on anyone who transferred during the preceding plan year – need transfer TO
and FROM information
• Termination File
• Information on anyone who terminated during the preceding plan year
• Applicant File
• All qualified applicant pools associated with each hire in the Hire File for the preceding
year.
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Employee File
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Employee file feeds the following reports:
Employee File
Work Force
Job Group
Vets/Disabled Utilization
Compensation
Census
Incumbency
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Missing race/gender
Job Groups - are job titles in the correct job groups
Mixed EEO/Job Groups
Same Job Titles different Job Groups
Disabled Status - Yes (Y) No (N) Unknown (U)
Veteran Status - Yes (Y) No (N) Unknown (U)
AAP Location - check for missing/incorrect AAP
Annual Compensation - check for missing, is everything annualized (part time to
full time equivalent)
Missing departments
Census Codes - any missing, are they accurate
Does every employee have a manager ID & AAP on the file
Employee File Data Validation
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Same Titles Different Spelling Same Title Different EEO/Job Groups
Mixed Compensation Missing Pieces
Employee Data Inconsistencies
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History Files
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Goal Attainment
Scorecards
Impact Ratio Analysis
Count Reports
Data Collection
History Files Feed:
History
File
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Note: for all promotions and transfers there must be a “TO” and “FROM” side of the
transaction.
Validate same information as Employee file plus:
Demotions – check for movement downward in EEO category for transactions coded
as PR / TR.
Promotion Confirmation – does the transaction meet the company definition of a
promotion? Are the TO and FROM side the same? If yes, is that accurate?
Duplicate Transactions – check for multiples of the same transaction on the same
date.
Termination Reason – check for Voluntary (v) Involuntary (i), validate against decode
table.
History File Data ValidationHires, Promotions, Transfers & Terminations
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Same To and From Job Title
Missing Termination Reasons
Two Termination Rows, No Rehire Row
Promoted after Termination, no rehire record
History Data Inconsistencies
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Applicant File
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Hire Impact Ratio
AnalysisHire Counts
Data Collection
Monitoring Scorecards
Applicant File Feeds:
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Disabled Status – check for Yes (Y) No (N) Unknown (U)
Veteran Status - check for Yes (Y) No (N) Unknown (U)
EEO Code – validate
Job Group – validate against decode table or last run AAP
Applicant ID – check for missing
Disposition – check for missing, validate against definition of applicant
Requisition – did requisition result in a hire, did requisition result in multiple hires
Requisition with no hires should be removed
Requisitions with only internal hires should be removed
Basic match of Applicant Name into Applicant Log – where match, and disposition
= hired, the information from the hire record trumps the applicant record (Race,
Gender, AAP, Job Group)
Applicant File Data Validation
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Hires with Unknown Race/Gender
Non-Applicant Disposition Reasons
One Requisition – Multiple AAPs One Requisition Multiple Job Groups
Applicant Data Inconsistencies
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AUDIT PREPARATION
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The following reports are due in the event of an audit:
• 3 Narratives
• Work Force Analysis
• Work Force Analysis
Include/Exclude
• Job Group Analysis
• Job Group Analysis
Include/Exclude
• Incumbency v Availability
• Placement Goals
• Compensation Item 19
• Goal Attainment
• Hire, Promotion and Termination Counts
• Veteran Monitoring
• Data Collection
• Utilization Analysis - Disabled
Reports reflect current plan year and
end-of-prior year unless audit notice
comes more than 6 months into your
current plan year, then midyear reports
would also be required
All of these reports must be accurate and reconciled with prior year.
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Preparing data for an Audit
• Are correct people in the AAP?
• Are includes/excludes appropriate?
• Are manager/supervisors notated?
• Is compensation data complete?
• Do you have adverse impact in any
area?
» Can you produce documentation?
» Are disposition codes correct?
» Have you performed a step analysis?
• Are transactions correct (hires,
promotions, transfers,
terminations)?
• Do the prior year totals – plus and
minus the transactions –
accurately reflect the current year
totals?
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Reconciling/Audit Prep
• Are the Hires accounted for in the
employee file?
• Have terms been removed from the
employee file?
• Is every hire in the applicant file?
• Are there hires in the applicant file
that are not in the hire file?
• Are there instances of duplicate
transactions with no corresponding
action– 2 termination rows but no
rehire row, for example?
• Are there requisitions with hires that
cross AAP’s – has the pool been
duplicated?
• Are there people in prior employee file
in 1 plan but in another plan for
current employee file?
• Can you account for demotions,
laterals and other movement?
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In Prior Employee file – Not in current – No term Row
In plan 10 prior year – in plan 20 current – no history record
In previous and current employee file – term row in history with no rehire row
In plan 10 prior and current employee file – termed from plan 12 and no rehire row
Advanced Data Inconsistencies
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Comparing 2015 to 2014• 1A +1
• 1B +2
• 1D – 3
• 2B +2
• 2E +4
• 5A +2
• 5B – 2
• 6A +4
• 7B +3
• 8A +23
Should find history
transactions to account for
each difference.
Compare prior year to current year, correct errors or ensure
you can explain discrepancies
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Here is the 1A hire to account for difference
Here are 2 hires in 1B to account for difference
But…in 5B there are 3 terms, not 2 – how do
we explain the difference?
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Check Include/Excludes to make sure they are correct
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Other Items to check
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Item #19 Compensation
This is high level, we will not be deep-diving into compensation concerns during this course. We do offer compensation
courses at PeopleFluent.
Make sure Comp data contains same groups as your AAP Job Group
Analysis
Check for mismatched job titles
Check for Mixed columns
Check for anomalies – high merit, low merit, high bonus, low bonus, etc.
Add data that helps explain variances – location, dept, shift, time in
position, etc.
Sort by title, then salary, look for potential disparities
If unsure of accuracy or you see issues in your comp data, consider get an
expert involved.
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Best Practices• Review data at time of AAP, do not wait until audit notice is received
– Reconcile prior year with current and review transactions
• Communicate placement goals, Utilization goals and hiring benchmark to anyone who makes
a decision about another person
• Monitor goal progress throughout the year
• Research all adverse impact
• Analyze compensation annually
• Review internal processes and ensure they are followed
• Document all employment decisions (applicant dispositions, hires, promotions, terminations,
compensation, etc.)
• Log all outreach and recruiting efforts
• List all jobs with the local or state workforce agency (3 exceptions)
• Review bulletin boards and tour facilities
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Questions