Preparing Your Data for AAP Development and Possible Audit€¦ · of BQ: •Non-Comparative...

Preparing Your Data for AAP Development and Possible

Audit Part I: Data Preparation

A presentation of the

BCG Institute for Workforce Development (BCGi)

Biddle Consulting Group Inc. Affirmative Action Plan (AAP)

Consulting and Fulfillment

• Thousands of AAPs developed each year • Audit and compliance assistance • myAAP™ Enterprise software

HR Assessments

• AutoGOJA™ online job analysis system • TVAP™ test validation & analysis program • CritiCall™ pre-employment testing for 911 operators • OPAC™ pre-employment testing for admin professionals • Video Situational Assessments (General and Nursing)

Custom Test Development & Validation

•“High stakes” test development •Validation studies in response/prevention to litigation

EEO Litigation Consulting /Expert Witness Services

• Over 200+ cases in EEO/AA (both plaintiff and defense) • Focus on disparate impact/validation cases

Compensation Analysis • Proactive and litigation/enforcement pay equity studies • COMPare™ compensation analysis software

Publications/Books • EEO Insight™: Leading EEO Compliance Journal • Adverse Impact (3rd ed.) / Compensation (1st ed.)

BCG Institute for Workforce Development

• 8,000+ members • Free webinars, EEO resources/tools

Speaking and Training • Regular speakers on the national speaking circuit

Biddle Consulting Group Institute for Workforce Development BCGi Memberships (free): ~8000+ members / 18,000+ HRCI credits to-date

Online community

Monthly webinars on EEO compliance topics

EEO Insight Journal (e-copy)

BCGi Platinum Membership (paid)

Includes validation/compensation analysis books

EEO Tools including those needed to conduct AI analyses

EEO Insight Journal (e-copy and hardcopy)

Access to the BCGi library of webinars, training materials, and much more …

www.bcginstitute.org

A few housekeeping items:

mailto:[email protected]

Contact Information Biddle Consulting Group, Inc. (BCG)

193 Blue Ravine, Suite 270 Folsom, CA 95630

916.294.4250 www.biddle.com

www.bcginstitute.org

Marife Ramos, PHR, SHRM-CP [email protected]

ext. 129

Tony Mentessi [email protected]

ext. 132




Agenda: Part I

Who’s Included in the AAP?

What Data do I Need?

What goes into Determining my Availability?

In Conclusion: Summary, Questions and Answers

Which employees are included?

• Each employee in the contractor’s workforce

Who are employees?

• The term ‘employee’ is broad enough to include part-time,

temporary, and full-time employees

• Are they on your payroll as of snapshot date (one day in time)?

• Field employees roll into manager’s location – move up the chain


Identifying the Corporate Initiative Employees:

Organizations are required to identify employees who work in one AAP

location while being on the payroll at another AAP locations and/or

report to a manager at another AAP location.

• Employees who physically work at a given location will have to appear in

the Workforce Analysis of that physical location (with annotation); but

nowhere else in that AAP.

• The employees who report to another location are included in all AAP

reports of that other location.


How to Define Corporate Initiative Employees:

Recommendations:

Include Employees in the AAP of their supervisor

or

Those who are in certain “levels” (e.g., Executives, pay grade, etc.)


An Affirmative Action Plan is a set of goal oriented management policies and procedures designed to identify and eliminate barriers to employment opportunities. By evaluating diversity in an organization’s workforce and ensuring personnel processes/procedures are fair to all, we get a better understanding if any impediments exist. This is accomplished by taking a look at the organization at a single point in time and analyzing everything that has occurred over the past 12 months



Data Requirements to Complete an AAP:

Employee Data – As of a specific date (snapshot date) in time Example – Using 12/31/2016, we want to capture all employees on the

payroll as of this date.

Transaction Data – Applicants, Hires, Promotions, and

Terminations that occurred during the 12 months prior to the selected snapshot date

Example – Using 12/31/2016 as the snapshot date, we would pull all

transactions that occurred between 1/1/2016 and 12/31/2016.

Employee Identifier – A unique identifier for each employee (e.g., Last four digits of SSN) Hire Date – The date the employee was hired Gender – Sex of employee (M/F) Race – Employee’s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran – Employee’s veteran status (Y/N) Disability – Employee’s disability status (Y/N) Job Code – The code assigned to each unique job title Job Title – The title of the employee’s job Job EEO Category – The EEO Category for the job title Salary – The Employee’s base salary amount Organizational Unit 1 – The department the individual works in Physical/Work Site – Where the employee is physically located Reporting Site – AAP reporting location

Includes all active employees on your payroll as of the snapshot date

What Data do I Need? Employees File

Typical Issues Encountered

• Missing Gender/Race information o Best solutions:

Re-survey the workforce to obtain this information Have the direct supervisor visually identify (if they are comfortable doing so)

• Missing Salary information o Use pay grade (if applicable) o Rank order by department

• Differing Job information o Ensure that job information matches across the files

What they applied for is what they were hired on as, what they were promoted to is the current title listed in the employee file, etc.


Additional Required Data Fields (if applicable)*: Pay Grade – Salary Band Full/Part Time Status – Full-Time or Part-Time employee Date in Job – Date the employee filled the current job Commission – Total additional compensation (in the form of commission) that the employee received Incentives – Providing employees with incentives to receive pay increase Bonuses – Total additional compensation that the employee received: holiday bonuses, quarterly bonuses,

annual bonuses, etc. Merit Increases – Performance appraisals Overtime Pay – Amount of overtime pay earned during the previous 12-month period Exempt/Non-Exempt Status – Employee’s FLSA status Hours Worked – Number of hours work in a typical workweek for part-time employees

*These additional fields are required during an OFCCP Audit


What Data do I Need? Applicants File

Gender – Sex of Applicant (M/F/U) Race – Applicant’s ethnicity (W, B, H, A, I, 2+, NHOPI, U) Protected Veteran – Applicant’s veteran status (Y/N/Did Not Provide) Disability – Applicant’s disability status (Y/N/Did Not Provide) Job Code – The unique code of the job title to which the applicant applied Job Title – The job title to which the applicant applied Job EEO Category – The EEO Category for the job title Reporting Site – AAP reporting location Applicant Type – Identifying if it was an external or internal candidate Application Date – The date the applicant applied

Include all applicants associated to the hires made within your transaction period

3. Individual Possesses

Basic Qualifications

3 Conditions

of BQ: •Non-

Comparative •Objective •Relevant

2. Contractor Considers

Individual for a Particular

Position

Required

Optional

Solicit Race/Ethnicity, Gender, Protected Veteran, & IWD

1. Individual Submits

Expression of Interest

(Electronic)

4. Individual Does NOT

Self-Eliminate

Before Offer is Made

5. Individual is an

Applicant

Retain Records

Individuals who meet all 4 “prongs” are applicants and will be included in the Personnel Transactions and Adverse Impact Analyses

What Data do I Need? Internet Definition of an Applicant

Employee Identifier – Hire’s unique identifier Gender – Sex of employee (M/F) Race – Employee’s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran – Employee’s veteran status (Y/N) Disability – Employee’s disability status (Y/N) Job Code – The code assigned to each unique job title Job Title – The job title the individual was hired into Job EEO Category – The EEO Category for the job title Hire Date – The date the employee was hired Reporting Site – AAP reporting location

Includes all new hires or rehires made within the transaction period

What Data do I Need? Hires File

What Data do I Need? Hires File


• How are Seasonal Employees handled?

• What if someone was hired outside the transaction period, but actually started working within the transaction period? o Is it when the decision to hire was made or when the start date occurred?

• Missing Gender/Race information

Employee Identifier – A unique identifier for promoted employee Gender – Sex of employee (M/F) Race – Employee’s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran – Employee’s veteran status (Y/N) Disability – Employee’s disability status (Y/N) Job Code From – The code assigned to the employee’s previous job, the one promoted from Job Title From – The title of the job from which the employee was promoted from Job EEO Category From – The EEO Category for the job title that the employee was promoted from

Includes all promotions made within the transaction period. Promotions depend on what your organizations definition of a promotion is

What Data do I Need? Promotions File

Job Code To – The code assigned to the employee’s previous job, the one promoted from Job Title To – The title of the job from which the employee was promoted from Job EEO Category To – The EEO Category for the job title that the employee was promoted from Promotion Type – Competitive or Non-competitive (if applicable) Promotion Date – The date the employee was promoted Reporting Site From – Previous AAP reporting location Reporting Site To – Current AAP reporting location




• What if someone was hired internally? o Is it a promotion or is it a hire? o Should transferred be analyzed?

• Mismatching job information between the Employee and Promotion files

• What if they were promoted multiple times during the transaction period?

Employee Identifier – A unique identifier for each terminated employee Gender – Sex of terminated employee (M/F) Race – Ethnicity of terminated employee(W, B, H, A, I, 2+, NHOPI) Protected Veteran – Terminated employee’s veteran status Disability – Terminated employee’s disability status (Y/N) Termination Code – The type of termination (e.g., voluntary, involuntary) Job Code – The code assigned to each unique job title Job Title – The job title of the employee at the time of termination Job EEO Category – The EEO Category for the job title Termination Date – Date the employee was terminated Reporting Site – AAP reporting location

Includes all terminations made within the transaction period

What Data do I Need? Terminations File

Includes all terminations made within the transaction period

What Data do I Need? Terminations File


• Should seasonal employees be included?

• Determining voluntary vs. involuntary terminations

• Are they still included in the employee file?

Applicants File

Hires File

Employees File

Jane applied for an open position and was hired within the transaction period.


Jane was terminated within the transaction period.

Applicants File

Hires File

Terminations File

Employees File


Applicants File

Employees File: reflect current jobs information

Jane was promoted within the transaction period.


Hires File

Promotions File

• A central premise underlying affirmative action is that, assuming all else being equal (and absent of discrimination), over time a contractor’s workforce will reflect the gender, racial and ethnic profile of those with the “requisite skills” in the labor areas from which the contractor recruits and selects.

• If a contractor’s workforce doesn’t reflect this labor profile, that’s when action-oriented programs and outreach & recruitment resources are used to help reach the observed profile.

• So what goes into determining what we “should” look like?


What we “should” look like is referred to as the “final availability”

• It’s an estimate of the number of qualified minorities or women available for employment in a given job group

• It’s a combination of internal and external availabilities (i.e., factors) to identify what those qualified to work in the job group are “supposed” to look like

• Once a final availability is calculated, we are able to compare the current composition of the job group to it an determine if underutilization exists


External Factor (i.e., typically census data)

• Step 1: Define the labor areas (local, state, national)

• Step 2: Assign census occupation codes to all jobs (487 available to choose from)

• Step 3: Mathematically weight census codes based upon representation within each job group

• Step 4 (Optional): Identify other relevant data besides the census (e.g., graduate data)

Internal Factor (i.e., “feeder” data)

• Step 1: Identify feeder jobs/job groups (those employees who are “promotable and/or transferable”)

• Step 2: Mathematically weight feeders based on relevance (e.g., flow/movement of internal employees)

IMPORTANT NOTE: Results are only as good as the amount of effort put into this process! But don’t get caught in the weeds … this is equal parts art and science!



Example: Happy Software location in San Mateo

Happy Software Corp. HQ (500 Employees)

Software Developers (2006-2010) Male Female White Black Hispanic Asian NHOPI AIAN 2+

SF MSA 80.0% 20.0% 42.3% 1.3% 3.1% 52.0% 0.1% 0.3% 0.9%

Male Female White Black Hispanic Asian NHOPI AIAN 2+

SJ MSA 78.1% 21.9% 30.1% 0.8% 2.3% 65.5% 0.0% 0.2% 1.2%

San Mateo: 30% Santa Clara: 30% Alameda: 12% Santa Cruz: 10% San Francisco: 10% Marin: 3% Contra Costa: 3% Stanislaus: 2%

“Trim” spurious and/or misleading labor areas, including those that have negligible contributions

What remains is the local labor area (with corresponding weights)


External Factor – Step 1: Define the Labor Area(s)

Zip Code or Manual Identification

• Census occupation codes (aka “census codes”) are links between your jobs and the external census data

• Each distinct job is assigned to one (or more) of the 487 codes

2010 Census Code Toolkit

• The census data for each code is weighted based upon it’s representation within each job group.


External Factor – Step 2: Assign Census Occupation Codes

2010 Census Code Toolkit.xlsx


External Factor – Step 2: Assign Census Occupation Codes

62.3% of the employees in this job group are in jobs assigned to code 7830


External Factor – Step 3: Weight Census Occupation Codes

• Miscellaneous (potentially) available data sets

o Graduate Data

o Internal/external training course attendees

o Mentorship programs

o ?


External Factor – Step 4: Identify relevant data other than that from Census

• Internal Factor:

o Positions are not always filled via external sources… it’s also necessary to identify internal sources of availability information

o Step 1: Identify “feeders” for all job groups

o Step 2: Weight feeders based on historical promotions data (i.e., data-driven… for starters… with a heavy dose of personal review because there will be crazy situations.

Target Job Group Weight Feeder Job Group

1A – Management 75.0 1B – Middle Management (Directors)

25.0 1C – Managers/Supervisors


Internal Factor – Step 1: Identify relevant feeders


Internal Factor – Step 1: Identify relevant feeders

Note: Job groups should never be a feeder for themselves.

50.0% of the internal movements into job group 7-03 come from job group 7-05


Internal Factor – Step 2: Weight feeders

• Factor Weights:

o The weight given to the internal and external availability data (i.e., factor) for each job group

o Identifies the relative “importance” of each set of data

• Assigning factor weights requires the used to ask the following question:

o “Out of 100 hypothetical movements into this job group, what number do I expect to come from a local recruitment area, national (or other reasonable) recruitment area, or an internal pool?”


Final Availability: Assigning Factor Weights

Raw (%) x Factor Weight = Weighted (%)


What We Should Look Like: Final Availability

Raw (%) x Factor Weight = Weighted (%) Final Availability (%) = Goal

In Conclusion: Summary, Questions and Answers

Summary

• The term ‘employee’ is broad. If part-time, full-time, and/or temporary

employees appear on your payroll as of the snapshot date, they should be

covered under an AAP.

o Be sure to identify any Corporate Initiative employees.

• Be careful of data collection pitfalls and do not get hung up on information

that you do not need for development.

o Reconciling data is essential for making audit ready Affirmative Action Plans.

o Only include applicants in which a selection was made during the transaction

period.

Summary

• The final product will only be as good as the data that you put in.

o Ensure you have all the required data and you’re determining your final

availability properly, as this will have a huge impact on the results.

o Make sure that you assign the appropriate Census Occupation Code for each

job title and review your Factor Weights & Feeders annually.

• Most importantly, if you need help, be sure to reach out and seek the

guidance that you require from an HR professional, Consultant, or Legal

Counsel.

Upcoming August Webinars

http://www.bcginstitute.org/

Preparing Your Data for AAP Development and Possible Audit€¦ · of BQ: •Non-Comparative...

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