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Affirmative Action FAQs
- What is Affirmative Action?
- What is an Affirmative Action Plan (AAP)?
- How are reports organized?
- What is a Job Group?
- What is the Availability Analysis?
- How is Internal Availability Determined?
- How is External Availability Determined?
- How are Internal Feeder and External Census Data Combined?
- How do I read the Incumbency vs. Estimated Availability Report?
- How are Placement Goals Determined?
- How do I read the Placement Goals Report?
Affirmative Action is a set of focused procedures and good faith efforts, which an employer carries out to ensure that equal employment opportunities are provided for all employees and applicants.
Two types of affirmative action plans are required – the AAP for Minorities and females, that consists of statistical and narrative sections and the AAP for Veterans and Individuals with Disabilities, that consists of a narrative section only.
In the AAP for Minorities and Females, employment statistics (for active employees on the payroll on the plan date) are evaluated at least once each year to compare the composition of the organization to the composition of the relevant labor pools by department, type of work, race, ethnicity and gender. In addition, personnel activity (usually hires, promotions, transfers, terminations, and applicant flow) is evaluated for a period of time, usually 12 months prior to the plan date, to ensure that employees are treated fairly without regard to race, ethnicity, gender or other discriminatory factors. The narrative reports of both AAPs describe and summarize the organization's policies, practices, results, good faith efforts and action plans to correct any deficiencies with regard to affirmative action.
The Job Group Analysis, Incumbency vs. Estimated Availability, Placement Goals, Significance of and Incumbency vs. Estimated Availability are organized by Job Group.
A Job Group includes one job or a group of jobs from the same EEO Category that are similar in content, compensation or opportunity. Similarity in content refers to duties, responsibilities; and similarity in opportunity refers to training, promotions, pay, mobility and other enhancement opportunities. Job groups are the fundamental unit of analysis in an AAP.
Availability is an estimate of the number of qualified minorities and women available for employment in a particular job group expressed as a percentage of all qualified persons in the job group. It serves as a benchmark against which the composition of the contractor’s workforce can be compared in order to determine whether barriers to equal employment opportunity exist in each job group. The availability analysis considers two factors: 1) internal and 2) external. It is from the external and internal factors that the representation of people available to perform the work in each job group is determined.
One or more internal factors reflect the opportunity for your organization to train, transfer, and promote people from within the organization. Feeder jobs are used to determine the percentage of a protected class available for employment opportunities within a particular job group at the organization. Feeder jobs are identified as positions that can provide a normal promotion path into each job group. While feeder jobs can be identified manually, the identification should be based upon past promotion activity or upon a reasonable expectation of future promotion activity.
For example, it is reasonable to assume that jobs in a mid-level manager job group can promote into a top-level manager group, even if no actual promotions occurred during the past year. Each job group will have different feeders and some job groups will have no feeders at all. If a job group has no feeders, only external availability will count towards total availability of people who can perform work within the group.
One or more external factors reflect the opportunity for your organization to bring in new employees from outside the organization. One factor used is the percentage of minorities and women with the requisite skills in a reasonable recruitment area. Data for external availability typically comes from the US Census Bureau.
Once the appropriate census data and feeder job/promotion statistics have been identified, external and internal availability are combined by considering the relative importance of each factor and by assigning appropriate factor weights. In the weighting procedure, a total weight of 100% is divided between internal and external availability factors.
For example, if 80% of the entrants to the job group are promoted from other job groups, then the weight on the internal factor(s) should be 80%. This leaves 20% weight for the external factor. This process is called calculating the weighted average. The overall “availability” for the group is determined by adding the two weighted percentages (external and internal) together.
The Incumbency vs. Estimated Availability report shows the employment and availability percentages for each job group and shows whether a placement goal is required. The column header key is as follows:
- Tot Emp. = Total number of employees in the job group
- Employment % Min = Percentage of employees in the job group who are minorities
- Employment % Fem = Percentage of employees in the job group who are women
- Availability % Min = Percentage of people available to work in the group who are minorities
- Availability % Fem = Percentage of people available to work in the group who are women
- Placement Goal? Min = Answers the question of whether a placement goal for minorities is set.
- Placement Goal? Fem = Answers the question of whether a placement goal for females is set.
A second report entitled Significance of Incumbency vs. Estimated Availability is also included. This report allows the organization to determine if the differences between employment and availability are statistically significant. This will allow the organization to determine areas that require the most attention.
The percentages of minorities and females employed within the organization are compared to availability percentages in the Incumbency vs. Estimated Availability report. When the percentage of minorities or women employed in a particular job group is less than would be reasonably expected given their availability in that particular job group, the contractor must establish a placement goal. There are four different rules that can be used. They are as follows:
- Whole Person Rule - A goal is set when availability exceeds employment by at least one whole person. Selecting this method typically results in goals that are considered practical and reasonable since it is impossible to hire or promote part of a person. From an implementation point of view, this rule makes the most sense to managers and is easiest to communicate.
- Any Difference Rule - A goal is set when availability exceeds employment by any difference. Selecting this method results in the greatest number of goals and represents a clear statement of good faith.
- Eighty Percent Rule - A goal is set when employment is less than 80% of availability.
- Compared to the Whole Person Rule- Selecting this rule will result in a greater number of goals when job group employment and/or availability numbers are small, and fewer goals when job group employment and/or availability numbers are large.
- Significant Difference Rule - A goal is set when availability exceeds employment by two or more standard deviations. Often favored by legal counsel, this rule is the least conservative and results in the fewest number of goals.
Placement goals serve as targets or objectives reasonably attainable by applying good faith efforts to your AAP. This number is not a quota. In all employment decisions, selections must be made in a non-discriminatory manner. The idea is that the company will make efforts to expand the pool of candidates by reaching out to areas that may have been previously overlooked and by doing so will increase the number of qualified minorities and women who are eligible for employment with the company.
The percentage next to the job group is a placement rate goal equal to your availability for that job group. If numbers do not appear under any of the columns then the percentage employment of women and minorities in your organization is appropriate.