Affirmative Action Plan Statistical Reports Review K. Williams, Business Consultant Julia Méndez, CAAP, PHR, CELS Principal Business Consultant Peoplefluent Research Institute
2013
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Agenda • • • • • • • • • •
Workforce Analysis Job Group Analysis Determining Availability Incumbency vs. Availability Placement Goals Goal Attainment Hire Analysis Promotion Analysis Termination Analysis Compensation Analysis Reports
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For AAPlanner Users • • • • • • • • •
Work Force Analysis and/or Organizational Display Job Group Analysis Census Reports Labor Report Incumbency v. Estimated Availability Availability Analysis Annual Placement Goals Goal Attainment Adverse Impact Analysis (Summary Counts, Analysis, Results) • Paragraph 11, Itemized Listing © 2012 Peoplefluent
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What is Affirmative Action? • Proactive action-oriented programs designed to ensure equal opportunity of qualified women, minorities, disabled individuals and veterans in the employment process • Enforced by the Office of Federal Contract Compliance Programs (OFCCP)
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Organizational Profile (Work Force Analysis) (41 CFR 60-2.11)
• A depiction of the staffing pattern within an establishment by department or organizational unit. • Contractor can either prepare an Organizational Display or Work Force Analysis
Purpose: • One method of determining existence of barriers to EEO in their organizations. • Provides an overview of the workforce that may assist in identifying departments where women or minorities are underrepresented or concentrated. © 2012 Peoplefluent
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Work Force Analysis • A listing of each job title ranked from the lowest paid to the highest paid within each department including departmental supervision. • For each job title, the total number of incumbents, the total number of male and female incumbents, and the total number of male and female by minority sub-group must be displayed.
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Work Force Analysis Look for Potential Glass Ceiling
Review: Are jobs properly ranking lowest to highest paid? Is there a concentration or under representation of minorities and/or females in any particular section of the workforce? Is there a glass ceiling? Do any departments appear segregated? Is their a supervisor identified in each department? © 2012 Peoplefluent
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Excl = Excluded from plan Incl = Included in plan AAP Statistical Reports Review 7
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Discriminatory Concepts Glass ceiling • An unofficially acknowledged barrier to advancement in a profession affecting women and members of minorities.
Concrete ceiling • The type of barrier minority women encounter.. This 'concrete ceiling' is due to minority women facing both issues of sexism and racism which makes it even more difficult to advance.
Glass door • This is a barrier that limits disadvantaged workers access to employment at high-wage jobs. © 2012 Peoplefluent
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Discriminatory Concepts Glass cliff • Typically women make it to the high levels of the organization, but are treated differently then men and often rated at a tougher scale causing them to be rated poorly and fall off the cliff
Glass wall • Invisible horizontal barriers causing females to not move laterally
Glass elevator/escalator • Rapid promotion of men over women, especially into management, in female-dominated fields such as nursing.
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Work Force Include/Exclude Example: Employee John Doe reports to Manager Fred Green AAP 1
Employee John Doe works in AAP 1
AAP 2
Manager Fred Green works in AAP 2
Exclude Employee John Doe will be marked with an Excl on AAP1 reports
Include Employee John Doe will be marked with an Incl on AAP2 reports
Employee John Doe will not be counted in the analysis for AAP1 (excluded) and will be included in the analysis for AAP2 (Included) © 2012 Peoplefluent
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Work Force Analysis – Included/Excluded
Included employee sits in:
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Work Force Analysis Summary
No Females/No Minorities © 2012 Peoplefluent © 2013 Peoplefluent
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Work Force Roster
Review •Are employees assigned to correct department? •Are employees assigned the correct job title, salary code and EEO code? •Are employees assigned the correct race/gender?
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Job Group Analysis (41 CFR 60-2.12; 2.13) Required Purpose • Groups job titles by similar content, opportunity and wage • Foundation for remaining reports • Provides utilization of job group as of the plan date
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Job Group Analysis (JGA) - Requirements • Must include a list of the job titles that comprise each job group. • If JGA contains jobs that are located at another establishment, the JGA must be annotated to identify the actual location of those jobs. • If the establishment at which the jobs actually are located maintains an AAP, the JGA of that program must be annotated to identify the program in which the jobs are included. © 2012 Peoplefluent
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EEO-1 Classifications 1A Executive/Senior Level Officials and Managers 1B First/Mid Level Officials and Managers 2 Professionals 40 CFR 60-2.12 (e) Smaller employers: If a contractor has a total workforce of fewer than 150 employees, the 3 Technicians contractor may prepare a job group analysis that utilizes EEO-1 categories as job groups. 4 Sales 5 Administrative Support Workers 6 Craft Workers 7 Operatives 8 Laborers 9 Service Workers © 2012 Peoplefluent
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Higher Education EEO Classifications 1 – Executive/Administrative/Managerial 2 – Faculty 3 – Instructional/Research Assistants 4 – Other Professionals 5 – Technical/Paraprofessional 6 – Clerical/Secretarial 7 – Skilled Craft 8 – Service/Maintenance 9 – Other Administrative © 2012 Peoplefluent
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Excluded employees will not be included on this report but will show on separate Job Group Include and Exclude reports
Job Group Analysis
Current Utilization of Protected class: Total Employees in Protected Class Total Employees in Job Group
Review Are their certain job titles that lack diversity? Are the job titles placed in the correct job groups? Are their certain job groups which lack diversity? © 2012 Peoplefluent
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Job Group Analysis – Included/Excluded
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Job Group Analysis Summary
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Job Group Roster
Review •Are the correct employees in each job group? •Are employees assigned the correct job title, race, gender, salary code and location? •Is everyone within the job group assigned the same EEO-1 classification? •Are employees reporting to another AAP excluded?
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Internal Availability (41 CFR 60-2.14(c)(2)) • Provides internal availability by protected class • Provides feeder job groups • Provides weight of feeder job groups Notes • Weight is calculated based on history for past 3 years (hires, promotions, transfers) • Demotions are not included
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Internal Availability
Review • Are feeders appropriate or anomalies? • Are all feeders represented? • Is the total availability ‘0’ for females and/or minorities? Feeder Job Groups
Weighted Availability
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Reasonable Recruitment/Labor Area (41 CFR 2.14(c)(1)) • Provides percentage that location hires from the Immediate or Recruitment Labor Area • Labor Area is one of two components that determines external availability • Second component is census code
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Reasonable Recruitment Area • Must Not Underestimate Availability: Ensure that contractor has not defined that area in a way that underestimates minority or female availability. • Consider commuting patterns: Including the availability of public transportation, approximate normal driving times, etc. in the labor area. • Relationship to EEO/AA Obligations: The immediate labor area definition should be consistent with the contractor's nondiscrimination and affirmative action obligations. © 2012 Peoplefluent
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Reasonable Recruitment Labor Area Distributions
Location where employee resides
Labor Area © 2012 Peoplefluent Assignment © 2013 Peoplefluent
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Reasonable Recruitment Labor Area Distributions
Expect recruiting areas for blue collar workers to be local. © 2012 Peoplefluent © 2013 Peoplefluent
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Recruiting Area Check Points • Does the contractor recruit in other areas, not reflected on the report, with higher minority/female availability? • Can the contractor expand its area to increase the numbers of minority group persons and women in the percentage of available workers? • Where do other nearby employers recruit to fill similar jobs? • Are the recruitment areas assigned to each job group reasonable given the pay or supply and demand? © 2012 Peoplefluent
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Census Codes and Job Titles (41 CFR 2.14(2)(g)) • Provides census code assigned to job titles within job group • Census code is one of two components that determines external availability • Second component is labor area
Notes • Census codes assigned based on job skills needed for each job title
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Census Codes and Job Titles • Purpose
2010 Census is anticipated to be available by 2nd quarter 2013
• Provides census codes assigned to job titles within job group • Census code is one of two components that determines external availability
• Second component is labor area
• Notes • Census codes assigned based on job skills needed for each job title
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Census Codes and Job Titles
Job Titles should “fit” Census Code assignment
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How are Goals Calculated? Current Utilization
External Availability Internal Availability
Apply Tests
Analyze Current Employee Population
Derive Total Weighted Availability
Check for Underutilization
Establish Goals © 2012 Peoplefluent
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Incumbency vs. Availability (41 CFR 602.15) • Compares Current Utilization to Total Weighted Availability
• Aggregates availabilities into two components – External » Requisite Skills in Immediate + Requisite Skills in Recruitment + Training Institutions – Internal » Available In Organization + Internal Company Availability
Notes Check for underutilization • Fewer females or minorities in a particular group than would reasonably be expected for their availability © 2012 Peoplefluent
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Incumbency vs. Availability
Availability is compared to utilization
Review • For job groups that have goals, is all or most of the weight given to external recruiting? • For job groups that don’t have goals, is all the weight or most of the weight given to internal movement? • Is total availability for either group ‘0’? • Are all sources being considered (i.e. universities, vo tech training program)? © 2012 Peoplefluent
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Placement Goals (41 CFR 2.16) • Provide a concise list of job groups with goals • Placement goals are equal to the availability in the Job Group – If job group does not have a goal, it will not be listed – If there are no goals for the plan there will be no report
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Placement Goals
Goal Placement Rate **NOT A QUOTA**
To Do Develop action-oriented programs Involve recruiters Involve hiring managers © 2012 Peoplefluent
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Goal Attainment (41 CFR 60-2.17) • Purpose • Only identifies those goals listed on the Placement Goal report • Shows the actual overall placements into each Job Group • Shows the actual placements into each Job Group by class underutilized • Shows whether or not goals were met
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Goal Attainment
Only job groups with a goal last year will appear on this report
Review • Are there any groups where the goal was not attained? If so, discuss why and good faith efforts which took place? • Are there groups which continue to have goals not met year after year? If so, why?
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Placement Detail • Listing of Hires, Promotions, and Transfers by job group for the year prior to the plan date • Lists promotions and transfers “to” job group • Provides supporting data for Goal Attainment
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Placement Detail
Review •Are all employees who were transferred between AAP locations included? •Are all promotions which crossed AAPs or job groups included? •Are all hires included? •Is the job title, job group, race/gender information accurate? © 2012 Peoplefluent
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Adverse Impact
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What is Adverse Impact? Under the Guidelines adverse impact is a substantially different rate of selection in hiring, promotion or other employment decision which works to the disadvantage of members of a race, gender or ethnic group.
80%
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Calculating Adverse Impact Applicants
Hires
Selection Rate/Percent hired
80 White
48
48/80 or 60%
40 Black
12
12/40 or 30%
30% / 60% = 50% < 80% © 2012 Peoplefluent
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Impact Ratio Analysis (41 CFR 602.17(d)(1)) • Purpose • Compares the selection rate for a target group to the overall selection rate • Evaluates employment activity to determine whether there are preliminary indicators of potential discrimination (i.e., applicant to hires)
• Includes • Separate reports for each category: Hires, Promotions and Terminations • An indicator is displayed for areas where there is adverse impact © 2012 Peoplefluent
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Applicant Roster • Provides supporting data for the Hires Impact Ratio Analysis • Lists all applicants included in the AAP • Should only contain those who meet the definition of an applicant • • • •
Meet the basic qualifications for the position Have expressed interest in the position Were considered for the position Have not self selected out/withdrawn from consideration
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Applicant Roster
Review • Is the race/gender unknown for those applicants which were hired? •Does the applicant information match up to the hires (e.g. EEO, job title)? •Are the disposition codes accurate and clearly define the last step of the hiring process and reason not selected? •Are all hires displayed in the applicant roster? © 2012 Peoplefluent
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Hires Counts
Review •Is there a large percentage of unknown race/gender? •Are there fewer applicants than hires? •Are there low ratio of applicants to hires? •Are there very large ratios of applicants to hires? © 2012 Peoplefluent
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Hires Analysis
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Hires Summary
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Promotions Counts
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Promotions Analysis
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Promotions Summary
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Total Terminations Counts
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Total Terminations Analysis
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Total Terminations Summary
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Involuntary Terminations Counts
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Involuntary Terminations Analysis
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Involuntary Terminations Summary
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Voluntary Terminations Counts
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Voluntary Terminations Analysis
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Voluntary Terminations Summary
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Monitoring Transactions Listing • Listing of Hires, Promotions and Terminations by job group for the year prior to the plan date • Lists promotions “from” job group • Provides supporting data for Impact Ratio Analysis
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Monitoring Transactions Listing
Review • Are all hires, promotions and terminations included? • Are job title, race, gender, and termination type correct? © 2012 Peoplefluent
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Step Analysis (41 CFR 60-3.4(c)) • If adverse impact is found in hiring decisions even after the pool of candidates has been refined, a Step Analysis MUST be prepared in order to determine which step of the selection process caused adverse impact • Minimum qualifications • Phone interview • Face-to-face interview • Written test • Drug test © 2012 Peoplefluent
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Compensation Review
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Compensation Review (41 CFR 602.17(1)(c)) • Review compensation at least annually. • Conduct the review job title. • Is there a difference between male/female average pay? Minority/non-minority pay? • What factors impact pay? • Can you explain any disparity in pay? © 2012 Peoplefluent
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Compensation Reports Item #11 – Required only if under audit • Provides the annualized compensation for males/females and minority/non-minority in each salary grade or job group/job title • Meets the requirement for item 11 on the OFCCP standard audit scheduling letter 2%, $2000 – Support Report • Provides an analysis of compensation between males/females and minority/non-minority and highlights areas where research is needed © 2012 Peoplefluent
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Paragraph 11, Itemized Listing by Job Title
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Compensation Analysis (2%, $2,000) by Gender
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Compensation Analysis by Race
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Reports to Submit to OFCCP if Audited • Work Force Analysis • Work Force Analysis Include/Exclude • Job Group Analysis • Job Group Analysis Include/Exclude • Incumbency vs. Availability
• • • • •
Placement Goal Goal Attainment Hires – Counts Promotion – Counts Termination – Counts (Inv./Vol.) • Item #11 • Narrative © 2012 Peoplefluent
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Most Critical Reports to Review for Accuracy • • • • •
Work Force Roster Job Group Roster Internal Availability Census Codes Reasonable Recruitment Labor Area Distribution
• Placement Detail • Applicant Roster • Monitoring Transactions Listing
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Reports to Review for Further Attention or Investigation • Work Force Analysis – signs of under-representation or concentration; signs of glass ceiling or other discriminatory indicators • Is there adverse impact in hiring, promotion and/or termination? • Do you have Placement Goals and have a action plan to meet the goals/good faith efforts? • Were goals attained from prior year? • Are there indicators of pay inequity? © 2012 Peoplefluent
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Upcoming Training Opportunities Webinars: Feb. 5, 2013 • Principles of Affirmative Action Planning Feb. 19, 2013 • Principles of Good Faith Efforts
Principles of AA Classroom Training: March 11 & 12 (Chicago) July 15 & 16 (Dallas) October 21 & 22 (New Orleans)
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Upcoming Training Opportunities Online Software Training: Feb. 20 & 21, 2013 • AAPlanner / Monitor April 16 & 17, 2013 • Pay Equity / Paystat April 17 & 18, 2013 • AAPlanner / Monitor
Compliance Reporting Center (CRC) • Feb. 19, 2013 • March 19, 2013
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Questions?
Send questions to
[email protected] © 2012 Peoplefluent
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Appendix
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Standard Deviation Calculation
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Calculating Fisher’s Exact
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Exact Binomial Calculation – Placement Goals
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Exact Binomial Calculation – Placement Goals
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