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Rosemary Cox

Rosemary Cox, M.S.

Senior Consultant
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Rosemary Cox is a Senior Consultant at DCI Consulting Group, headquartered in Washington, DC, where she provides consultation specific to equal employment opportunity and affirmative action statutes and regulations. Her area of expertise includes AAP reporting, recruitment process and metrics, strategic audit discussions, mock audits, compliance and diversity/inclusion training and strategy.

Rosemary holds a MSA in Human Resources from Central Michigan University, has senior certifications through, SHRM, HRCI, AAAED and the State of Ohio. With 20 years of human resource compliance experience, she supports a variety of corporations in various industries, writes for the DCI Blog, conducts webinars and training.

Rosemary is a member of several professional organizations including the Ohio Industry Liaison Group (OILG), Society for Human Resource Management (SHRM), American Association for Access Equity and Diversity (AAAED).

Rosemary Cox ’s Recent Posts

The time has come that businesses need to take a serious look at their websites and accessibility.  A Florida federal judge has ruled Winn-Dixie’s website violated the Americans with Disabilities Act. 

“The factual findings demonstrate that Winn-Dixie’s website is inaccessible to visually impaired individuals who must use screen reader software,” Scola wrote.

“Therefore, Winn-Dixie has violated the ADA because the inaccessibility of its website has denied Gil the full and equal enjoyment of the goods, services, facilities, privileges, advantages or accommodations that Winn-Dixie offers to its sighted customers.”

Sheridan Walker, CEO of HirePotential, Inc. believes that this will be a game changer on website accessibility.

Under Section 503 the only requirement is to provide an accessibility statement giving applicants information on how to obtain assistance in the employment process.   Is this enough?  What if the disability does not allow them to read the online statement, how can they be given equal opportunities for employment?

It’s really much more important than simply complying with Section 503; it is about access to the services and products that your organization produces.  The large and growing market of people with disabilities has $175 billion in discretionary spending, according to the U.S. Department of Labor. $175 billion is more than four times the spending power of tweens (8-14 year-olds), a demographic sought after by businesses.

There are several things you can do, on your own, to see if your site is accessible or you can contract someone to help you make that determination.   Stay tuned as we provide you with accessibility tips in future blogs.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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The 43rd annual national conference for the American Association for Access, Equity, and Diversity (AAAED) was held June 7-9, 2017 in Scottsdale, Arizona. This conference brings together diversity professionals from across the country, including EO directors, EEO specialists, affirmative action officers, human resource professionals, labor relations advisors, and other equity and inclusion professionals. This year’s conference theme, “We are known by the tracks that we leave,” aimed to recognize the importance of developing and leaving a more diverse and inclusive legacy than we found. DCI Consulting staff members were well represented in a number of presentations, and DCI’s Rosemary Cox received The AAAED President’s Award for her work as the AAAED Conference Chair.

Notable session summaries can be found below.

Sr. CAAP session: Case Study Review and Analysis: An Interactive Discussion on Federal Contractor Cases in the News 

The AAAED pre-conference Sr. CAAP (Certified Affirmative Action Professional) session called “Case Study Review and Analysis: An Interactive Discussion on Federal Contractor Cases in the News” was led by Keli Wilson, DCI Consulting Group. The objective of the class was to come prepared to discuss pre-specified OFCCP cases in the news in order to critically review the outcome and what lessons could be learned for navigating an OFCCP audit and negotiating terms for a conciliation agreement.

AAAED Outstanding Plenary Sessions

The conference played host to two interesting plenary sessions:

Plenary #1:“What to Expect/Recent Changes Under the New Administration”

The November 2016 election ushered in a sea change in federal government programs and policies. This panel of national experts discussed the potential implications for civil rights, equal opportunity, and diversity laws and the administration of related programs.  With the proposed budget and talk of a merger of EEOC/OFCCP the panel spent a good deal of time weighing the pros and cons of these decisions.

Panelists: David Cohen, President, DCI Consulting; Michelle Duncan, Partner, Jackson Lewis PC; David Lopez, Partner, Outten and Golden, formerly EEOC General Counsel; Dr. Christopher Metzler, CEO, HFW¥ and former Associate Dean, School of Continuing Studies, Georgetown University; and Shirley J. Wilcher, AAAED Executive Director (Moderator).

Plenary #2: “The New Face of America: A Conversation about the Politics of Civil Rights”

A panel of local and regional experts provide their perspectives on the implications of recent and proposed changes affecting civil rights in government, business, communities and education.  This panel explored the challenges we now face and potential ways to move forward.  The passion for civil rights and the deep concern for the rollback of policies was truly apparent with each panelist.

Panelists: Dr. Ann Hart, President of the Maricopa NAACP; The Honorable Reginald Bolding, AZ State House of Representatives and Chair AZ State Legislative Education Committee; Carlos Galindo-Elvira, Regional Director, Anti-Defamation League; Mary Jo O’Neill, Regional Attorney, EEOC; Dr. James Wermers, Faculty Fellow, ASU Center on Race and Democracy; Kevin Salcido, Vice President of HR and Chief HR Officer, Office of Human Resources, ASU.

AAAED New Professionals Academy (NPA)

For the second year, AAAED offered a two-day workshop for new professionals.  The NPA is designed to introduce new Equal Employment Opportunity, Affirmative Action and Diversity Professionals to the substantive and operational fundamentals of the job including Diversity and Inclusion, Effective

Supervision and Career Planning.   DCI’s Rosemary Cox taught a section on “Beyond Compliance, Effective Recruitment & Retention Business Best Practices to Recruit and Retain Excellent Employees.”  The recruitment section was designed to be interactive, challenging the participants to think creatively about recruiting and explore solutions to the challenges surrounding educating the organization first (building a business imperative) rather than “warm body hiring.”

What you Always Wanted to Know About Pay Equity Analyses but Were Afraid to Ask 

Mike Aamodt presented the session, “Everything you always wanted to know about salary equity analyses but were afraid to ask.”  In the session he talked about how to properly interpret the gender wage gap, types of salary equity analyses, and the basic steps in conducting salary equity analyses.

Using Metrics to Identify Diversity Opportunities

The AAAED conference session called “Using Metrics to Identify Diversity Opportunities” was co-presented by Keli Wilson and Amanda Shapiro, DCI Consulting Group. The goal of the session was to demonstrate how to capitalize on the affirmative action plan development (e.g., utilization concepts) for diversity plans. In addition, time was spent on identifying and discussing the pros and cons of different benchmarking data sources to use in diversity metrics. Presenters went through an interactive exercise that allowed attendees to participate and interpret a sample diversity dashboard that incorporated comparisons of the talent acquisition stages to a data benchmark. Information was shared about what action items for diversity may come from each talent acquisition stages. Finally, the presenters introduced an informative yet underused metric related to the amount of time it takes for critical employment outcomes to happen for different groups of interest. The attendees were provided with a holistic understanding of where they can be adopting metrics in their diversity and inclusion programs to further identify gaps and measure progress.

Diversity Learning in a New Era: Strategies to Include, Unite and Move Forward in the Aftermath of the 2016 Presidential Election

Alison Akant, with DiversityEdu, led a session focused on teaching rather than training when it comes to diversity. Help attendees learn to interact in diverse situation or gain skills needed to be a part of an inclusive environment rather than directed training which often implies obedience. Some additional recommendations are listed below.

  • Examine gaps between mission and employee experience. One method to learn about this is to utilize a survey. Another suggestion was to do an exercise where employees read the mission and note (1) what the benefits are and (2) their responsibilities in carrying out the mission.
  • Inform, don’t direct. This will reduce resistance and provide choice.
  • Base learning in fact, in research.
  • Narrative strategies can be helpful – story-telling is a powerful aide.
  • Put the diversity training in the right context – it’s not training for them, but rather useful information for everyone.
  • Teach about privilege, as well as unconscious bias.
  • Be active part in staying up-to-date on current issues (internally and externally) to inform training needs.

How to Navigate the Intersection of Affirmative Action and Diversity

Michelle Duncan, an attorney with Jackson Lewis P.C., led a session focused on the intersection of affirmative action and diversity. Her talk provided historical, legal context for affirmative action and diversity. She also focused on the business case, citing the rise of publications like Diversity Inc.’s “Top 50” list, which experienced a rise in applications, with 75 in 2001 to 1,215 in 2013. Listed below are a few recommendations highlighted in her presentation.

  • When utilizing a diverse slate in your selection process, the messaging is very important.
  • If a diversity program wants to utilize preferences, veteran and disability preferences are less risky. If exploring this option, using an “add to” strategy was preferred.
  • “Stay” interviews could be a great strategy to learn what is retaining your diverse talent, as well as pick up on early indicators.
  • Recommended to include pay in the discussions surrounding your D&I program.

Going Beyond Diversity to Inclusion Through Engagement

Lana Petru, with Liderology Consulting Group, led an interactive session focused on how organizations can enhance their D&I program through the engagement of employees in a variety of ways. The benefits of engaged employees were highlighted, including the high likelihood that an engaged employee (as opposed to unengaged) would be strong on customer service and recommendation of their employer. Petru focused on the “engagement framework” which encourages a diverse team, focus on organizational results, and a culture/environment where all can thrive. Recommendations listed below.

  • Utilize Employee Resource Groups (ERG). Ensure that there are senior official engagement/involvement to demonstrate importance. Can utilize ERGs to achieve diversity and inclusion in recruitment, talent development, and business solutions, among others. Success can be measured through retention, engagement, talent development and other contributions to business.
  • For global organizations, consider having a global diversity council where each country is represented.
  • Integrate supplier diversity into corporate goals. Company can sponsor scholarships or educational opportunities for diverse suppliers, or can also offer formal training and mentoring.
  • For the attraction, and retention, of veterans, have things in place for their spouses, too. One recommendation is to have an ERG devoted to this.
  • Use of mentoring program and ensure that mentors receive cultural competence training (among other training needs, not all employees make a good mentor).
  • Determine readiness for engagement through D&I strategies such as a change management survey, engagement survey, and/or focus groups.
  • Monitor results of programs and celebrate wins!

AAAED Keynote Speakers

“Civil Rights Update: A View from the Agencies”

The luncheon speakers for Friday of the conference were both tremendous.  Catherine E. Lhamon, Chair of the U.S. Commission on Civil Rights, was appointed by President Obama to a six-year term on the Commission on December 15, 2016 and the Commission unanimously confirmed the President’s designation of Lhamon to chair the Commission on December 28, 2016. Before coming to the Commission, Lhamon served as the Assistant Secretary for Civil Rights at the U.S. Department of Education until January 2017.

Ms. Lhamon gave a powerful speech with examples of continued concerns with violence and harassment in our public school systems.  Her poignant examples of children harassing (bullying) children over race that has increased since the election was particularly disturbing.  The fact that the public never hears of these cases seemed particularly concerning to the audience.

Elizabeth (Isa) Cadle, District Director of the Phoenix District Office of the U.S. Equal Employment Opportunity Commission (EEOC) and as a member of the Senior Executive Service, effective Oct. 30, 2016. Ms. Cadle served as the Deputy District Director in Phoenix since 2011 and as acting district director since November 2015.

Ms. Cadle provided ongoing cases of discrimination but also provided insight on what employers can do to ensure these do not happen in their organizations.  She discussed the state of the EEOC and only touched on the merger.

OFCCP Acting Director, Tom Dowd, Guest Speaker

It was a special honor to have Tom Dowd, Acting Director of OFCCP, speak at the AAAED conference. He emphasized a focus on two major areas: (1) that OFCCP not compromise the quality of OFCCP audits which has led to fewer and may lead to even less annual compliance reviews; and (2) providing compliance support while balancing audit work. Also, as it relates to the EEOC and OFCCP proposed merger, he mentioned that it is for Congress to decide at this point.

By Amanda Shapiro, Senior Consultant; Keli Wilson, Principal Consultant; Mike Aamodt, Principal Consultant; and Rosemary Cox, Senior Consultant at DCI Consulting Group 

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President Trump recently released two items of interest to this industry: 1) an Executive Order on March 13th directing the Director of the Office of Management and Budget to propose a plan with the assistance of each agency to reorganize the executive branch; and 2) a proposed budget on March 16th or Fiscal Year (FY) 2018.  Both of those documents propose improved efficiency and, more importantly, reduced budgets. Specifically, the President’s proposal includes a 20.7% budget cut to the Department of Labor (DOL); see table below.

While the President’s proposed budget does not specifically name the OFCCP within its potential cuts, with a 20.7% overall reduction to the DOL budget, we can only assume that cuts will come to the OFCCP as it’s an agency within the DOL. The proposal does discuss the strengthening of the military and assistance for Veterans; with that in mind, we can assume that VEVRRA will continue to be a focus going forward.

2018 Discretionary Overview by Major Agency

It is unknown how the budget will play out for the OFCCP without a Labor Secretary in place and with the Executive Order mandating a proposed plan for the reorganization of the executive branch.   Historically, a budget reduction for OFCCP meant changes in a) staffing and b) travel funds, which impact enforcement activities. Hiring freezes mean no additional experts (statisticians, economists, I/O psychologists) for specific enforcement areas, and less money to spend on litigation; a staff reduction would mean fewer resources for day-to-day compliance review work. A reduced travel budget means fewer on-site reviews and less OFCCP participation in events such as conferences that would require more than local travel.

DCI will keep you informed of any new developments.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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DCI has just learned that OFCCP began to send out audit scheduling letters on March 17th.  At this time we are not certain how many were sent out, but we do know that 800 CSALs (Corporate Scheduling Announcement Letters) were sent to contractor establishments last month.  It is critical that corporate compliance representatives notify individual establishments in their organization to be on the look-out for any official OFCCP correspondence.  If you did receive a scheduling notice, please notify DCI immediately so that we can assist you with the audit process.

To read the audit distribution notice, please click here.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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What does this mean for you?  The current form expires on January 31, 2017, so Federal Contractors will need to update their self-id forms.  For some of you this may require a system update and for others it may simply be using the new form.  Since the new form was just released today contractors should not be held in violation for utilizing the old form, however, systems should be changed as soon as possible.

The new form is located on the Department of Labor/OFCCP website

As a reminder, the voluntary self–identification form is an OMB–approved form and, as such, its content cannot be altered or changed.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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On September 30, 2016, the Office of Management and Budget (OMB) advanced a proposal with a notice to the Federal Register to create a new racial or ethnic category.

Currently people from the Middle East and North Africa are considered “white” in the U.S. Census.  The proposed change could add a new category to the list. Middle Eastern or North Africa, or MENA, is broader in concept than Arab (an ethnicity) or Muslim (a religion).  It would include anyone from a region of the world stretching from Morocco to Iran, including Syrian and Coptic Christians, Israeli Jews and other religious minorities.

What will the data will be used for once collected?  According to the OMB, the data will be used for:

  • Enforcing the requirements of the Voting Rights Act;
  • Reviewing State congressional redistricting plans;
  • Collecting and presenting population and population characteristics data, labor force data, education data, and vital and health statistics;
  • Establishing and evaluating Federal affirmative action plans and evaluating affirmative action and discrimination in employment in the private sector;
  • Monitoring the access of minorities to home mortgage loans under the Home Mortgage Disclosure Act;
  • Enforcing the Equal Credit Opportunity Act;
  • Monitoring and enforcing desegregation plans in the public schools;
  • Assisting minority businesses under the minority business development programs;
  • Monitoring and enforcing the Fair Housing Act.

So what does this mean for Federal Contractors?  Well, we have plenty of time to think about it as it would not go into effect until the 2020 Census.  If this passes contractors will most likely need to change their paper and online self-id forms to include the new race categories and re-survey the workforce.

The good news is that maybe with these changes, the OFCCP and the EEOC will sync their race/ethnicity categories. Only time will tell.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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Really, I Come Here for the Food: Sex as a BFOQ for Restaurant Servers

Michael Aamodt, Principal Consultant at DCI Consulting Group, wrote an article featured in SIOP’s TIP publication, January 2017.