|"Getting Ready for an Affirmative Action Plan"
|FROM AFFIRMATIVE ACTION SOLUTIONS, December 2001
© 2001 Business & Legal Reports, Inc.
At the end of the calendar year most government contractors find themselves gathering data to update the annual Affirmative Action Plan. The ideal effective date for a Plan is January 1, based on year-end data through the 31st of December. Calendar year end is the best time to audit data.
There are several reasons for this:
(1) A year end audit of personnel data will ensure your records are current.
(2) Data such as address need to be current for distributions of W-2 statements at year-end.
(3) For active and terminated employees, year-end pay information including bonus or commissions is also based on an actual year end number and does not require any type of prorating or adjustments.
(4) A calendar year end headcount is the required benchmark for operational purposes. The headcount audit can also help to identify corrections to employee information such as department codes or job titles.
While you are conducting the overall audit you should also gather specific data to prepare the affirmative action plan update. Company census data required:
- Employee Name
- Department Name and Code
- Job Title Name and Code
- EEO Classification Code
- Race Designation Code
- Sex Designation Code
- Annual Pay (Hourly Rates should be annualized)
- Salary Grade Code
- Employment Status (Full Time, Part Time)
- Hire Date
- Supervisor Name and Title
- Hiring Location
- Work Location
This data can be compiled in an electronic spreadsheet format. This works well because it is easy to identify errors and missing data. Various sorts on primary data -department information, job titles, EEO classifications, supervisor or location enable checks of the information to ensure consistency and identify anomalies. Correct the data in the spreadsheet format prior to utilizing the data.
Additionally, tracking applicant flow on a calendar year basis is easy for record storage purposes. Applicants are required to be kept for two years. This provides an opportunity to capture data and retrieve it based on years. It is easy to identify when you want to destroy obsolete application records. "It's time to toss the 1999 files."
Applicant flow-related regulations requires employers to track qualified applicants for open positions. You need to track name, position applied for, date applied, date interviewed, disposition of interview, hire date, hiring location, EEO code, race code, sex code, Vietnam veteran status and birth date.
In any OFCCP audit a key area for review and testing is the applicant flow. The first impression of available data is essential to getting through this review. Not having the required data will lead to questions about the quality of the applicant review, candidate selection and employment process.
Review compensation data based on actual pay to range midpoint ratios. Also review employees with pay below the minimums of the assigned ranges. Review this data with regard to race and sex. The OFCCP will be reviewing pay equity issues. Keep in mind the OFCCP can recommend to the EEOC allegations of discrimination based on pay.
The opportunity to do a self-audit will address many concerns and allow you to take corrective action prior to a third party investigation. Voluntary corrective action is much easier to implement than a third-party directive.
Philip A. Barquer, SPHR
Is President of HR Alternatives, Inc., located in Newport Beach, CA, providing HR services locally and nationwide. He can be reached at (949) 453-6250 or at their website: www.hralternativesinc.com