Covered contractors conducting business with the federal government have Equal Employment and Affirmative Action obligations to fulfill that are enforced by OFCCP. As a new contractor, our healthcare client decided to outsource their Affirmative Action Plan (AAP) process and contacted DCI Consulting Group. In addition to the various components of an AAP, the client requested educational and technical guidance because they were new to the contractor community. In particular, the client needed assistance in the following:
- Important dates relating to their AAP cycle
- Data submission guidelines
- Revision of job groups and job titles
- Utilization analyses
Through this project, DCI provided educational and technical assistance to this new contractor to ensure that it was able to quickly and efficiently become compliant with the regulations within the required 120 days after their contract took effect. DCI engaged the client in actively reviewing and developing the structures in place for creating the AAP.
Data Pull: An AAP plan date was selected based on the company’s compensation merit cycle so as to correspond with the timing of their compensation analysis. Data requirements were reviewed with the client to clarify necessary data points and timeframes for accurate data submission.
Job Groups: The client’s custom job groups were reviewed for grouping of job titles in similar wage, content, and opportunity. Once finalized, the job groups were matched to Equal Employment Opportunity categories.
Utilization Components: All active job titles were linked to appropriate occupational census codes by using information from the contractor’s job descriptions and the O*NET site when additional job information was needed. Based on the contractor’s recruitment areas, census geographic areas were identified for each AAP location. Finally, a trend analysis was conducted on the contractor’s promotions and hires data to determine the rate of internal promotions when filling open positions and the typical job groups feeding into those positions.
Training: Training was conducted for the client’s managers and executives, as well as, staff in recruiting and human resources. These trainings were comprised of a combination of on-site and online training. Regulatory obligations and key basics for creation and implementation of the AAP were covered in a relevant manner for the participating group.
This project yielded a fully compliant AAP to be used as a living document during the upcoming plan year. By the time of plan roll-out, the contractor had knowledgeable staff and plan owners ensuring a best practice implementation of the AAP. Next steps for human resources risk management were identified for readying the contractor for potential future OFCCP compliance reviews.
Covered government contractors must become compliant with EEO-related regulations within 120 days after their contract takes effect. DCI provides efficient and thorough AAP development to ensure clients have their Affirmative Action Program implemented in a manner that will stand up to OFCCP compliance review scrutiny.
Michael Aamodt, Principal Consultant at DCI Consulting Group, wrote an article featured in SIOP’s TIP publication, January 2017.
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 GroupRead More