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:
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.
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