Strengthening your Affirmative Action Plan

It's very important to have a solid affirmative action plan. Revisiting this at least once a year is imperative to refresh, update, and strengthen the plan to ensure you are not only enforcing the plan but also following the Office of Federal Contract Compliance Programs' affirmative action mandates.

The OFCCP states that all federal contractors and subcontractors must have an affirmative action plan in order to be in compliance with Executive Order 11246, as amended; Section 503 of the Rehabilitation Act of 1973, as amended; and the Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended, 38 U.S.C. 4212.

Federal contractors and subcontractors with 50 or more employees and a contract of $50,000 or more - to develop and maintain a written affirmative action program (AAP).

An affirmative action plan refers to policies that take in factors including race, color, religion, gender, sexual orientation or national origin into consideration in order to benefit an underrepresented group in areas of employment, education, and business.

A plan may include the creation of an organizational display, which is a detailed chart of the contractor’s organizational structure. For each organizational unit, the display must have the name of the unit and the job title, race and gender of the unit supervisor, and the total number of male and female incumbents and the total number of male and female incumbents in Blacks, American Indians, Asians, Hispanics, and whites other than Hispanics.

The plan may also identify areas that need improvement. For example, the plan may identify the underutilization of minorities and women in certain job groups where external hiring opportunities occurred. It may express concern regarding low minority and female applicant flow rate resulting from inadequate recruitment for both job groups.

Then corrective actions could be expressed on how to rectify the problem. For example, the plan may recommend notifying management and professional recruitment sources, in writing, of the company's interest in attracting qualified minorities and women to apply for job openings. It may also recommend expanding the recruitment program to colleges and universities with a significant percentage of minority and female students.

The Department of Labor recommends additional action-oriented courses to take to strengthen the affirmative action plan. These include conducting annual analyses of job descriptions to ensure they accurately reflect job functions, evaluating selection methods that may have a disparate impact to ensure that they are job-related and consistent with business necessity, training personnel and management staff on proper interview techniques, and placing help wanted advertisement, when appropriate, in local minority news media and women's interest media.

Other plans of recommended courses of action include disseminating information on job opportunities to organizations representing minorities, women and employment development agencies when job opportunities occur, making job descriptions available to recruiting sources and available to all members of management involved in the recruiting, screening, selection and promotion processes, and actively recruit at secondary schools, junior colleges, colleges and universities with predominantly minority or female enrollments.

The company can also offer counseling to assist employees in identifying promotional opportunities, training and educational programs to enhance promotions and opportunities for job rotation or transfer.