Affirmative Action Plan Preparation
Employers who are subject to OFCCP regulation are required to have a written Affirmative Action Plan (AAP) which is updated annually. While you are not required to submit your plan to the OFCCP every year, if the OFCCP selects you for an audit, you must provide your AAP. The risks and potential liabilities for not having a well-written, current AAP on file are significant, and new OFCCP requirements only add to the complexity of preparing your AAP. Many HR professionals, however, don’t necessarily have the background or the time to create the full AAP the OFCCP requires. Very simply your AAP must include specific statistical analyses and reports. It should compare your company's minority and women recruiting and hiring efforts with census data corresponding to your “reasonable” recruiting area for the available pool of minority and female candidates. You must also collect data on veterans and disabled workers and compare those with benchmarks and goals. You must also self-audit your compensation and be prepared to discuss.
You and your AAP have two basic responsibilities: to provide an accurate picture of your company’s hiring efforts, and to portray your company in a positive and accurate light. Achieving these objectives, however, may not be as simple as it appears. Potential problems exist all along the way; starting with the recruiting and census data you are using. Next come the reports your AAP is required to include, as well as your plan for correcting any deficiencies you may have found. The starting point for dealing with all of these is to make sure you understand how to prepare an AAP from beginning to end—company recruiting and hiring data, census data, analysis, required reports, and your narrative. Please join Cheryl Behymer, attorney at law, as she guides you step-by-step through how to prepare your AAP and offers practical suggestions for interpreting and presenting your results in an actionable manner.
Just a sampling of what this webinar will cover:
- How to assemble your applicant data in a manner that fits your AAP template
- How new LGBT, pay transparency, and other new OFCCP requirements impact your AAP preparation
- Whether you need to include unsolicited applications for employment as part of your applicant pool
- That you need to be focused on not just the recruiting of minorities and women but also veterans and the disabled, and analyze and report your efforts
- Different sources of census data, as well as census data service providers, and how this data should be used to analyze your recruiting efforts within your reasonable recruiting area
- How to prepare the required AAP reports—utilization, workforce, etc.
- What your plan narrative should discuss including: responsible person(s), problem areas, obtainable goals, systems you have in place for auditing and reporting, etc.
- Common mistakes. For example: revealing confidential information, admitting to discrimination, including goals that can’t be achieved, referring to hiring “quotas”—quotas are illegal
- Topics your plan narrative should cover: actual company employment experience of women and minorities compared with estimates based on an analysis of female and minority populations in the employer's reasonable recruiting area, policies and procedures which could adversely impact hiring, paying similarly situated employees fairly without regard to minority or gender, etc.
- AND MUCH MORE!
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