For many government contractors, January marks a time for updating their Affirmative Action Plans (AAP). While a company is not required to adopt a calendar year for plan administration, many choose to do so because it’s more convenient when it comes to pulling the necessary reports needed in a plan.
However, many HR Professionals inherit plans from their predecessor that they suspect are incomplete or – worse yet – step into a situation where a plan has not been done at all. Where do you begin? What do you do?
Well, an affirmative action plan is a dynamic program designed to foster inclusion of females, minorities, disabled individuals and veterans to ensure that the covered contractor is fully committed to the principles of equal employment opportunity.
There are many elements to an AAP. There are both statistical and narrative components. Required statistics include an Organizational Profile, Job Group Analysis, Report on Prior Year Goals, and Availability Analysis, a Comparison of a Company’s Existing Incumbents to the Availability Data, Placement Goals (designed to overcome gaps or underutilization in an organization’s workforce), Adverse Impact Analysis of a Company’s personnel data (including Hire, Promotion and Termination data). Additionally, there’s also the need to analyze a workforce’s compensation information to identify any discrepancies when it comes to how groups (on average) are paid in comparison to one another.
Narratively, the plan should also designate a representative who is responsible for implementing the plan within the organization. In doing so, this representative should have the authority, resources, support of and access to top management to ensure the effective implementation of the AAP.
The plan should also have an “Identification of Problem Areas” section where the organization analyzes and reports any barriers to achieving Equal Employment Opportunity in the workplace. “Action-Oriented Programs” is a section in an AAP that is designed to discuss steps undertaken or to be undertaken by the contractor in correcting problem areas that have been identified (whether it be in one’s recruiting practices, interviewing and selection processes, compensation practices, performance management or any other aspect of employment). Finally, there should be an “Internal Auditing and Reporting System” section that spells out how the contractor intends to monitor its activities and practices over time.
These plans need to be maintained and updated. Not only because headcounts change over time, but so do jobs, departments, reporting structures, management practices – all of which can have an impact on the statistical reports, as well as the company’s business outlook – whether good or bad – as far as that may either help or hinder achieve the plan’s objectives.
In other words, an Affirmative Action Plan is not just a “fill in the blank” exercise. For some that take that path, it may be a short term approach to having a plan document. However, plan documents that aren’t supported in practice have a tough time if the company gets audited. Penalties can range from Conciliation Reporting to the temporary or permanent debarment from government work by the Department of Labor (depending upon the severity of the violations).