|
|
|
|
|
location with less than 50 employees:
include the employees in a separate AAP;
include them in another AAP where the personnel function supports this location;
include them in the AAP of the location to which they report.
If the hiring authority for a particular employee is made at a higher level at another location, that employee must be included in the AAP of the hiring location.
Employees who fall into one of these "exceptions" must be "annotated" in two separate plans - the plan in which they are included, and the plan where they actually work. This annotation requirement cuts across geographic lines and could be an administrative nightmare for large, diversified companies.
Companies can now request special permission from the OFCCP to complete their plans by functional or business units that cut across geographic locations. However, the regulations also state that these agreements "...cannot be construed to limit or restrict how the OFCCP structures its compliance evaluations." It appears that the OFCCP could still conduct compliance reviews by individual facility, which would negate the very reason for entering such agreements in the first place.
The Organizational Profile is a new report that consists of a graphical, tabular chart, text or spreadsheet presentation of the company's organizational structure. It shows each organizational unit and its relationship to other organizational units. Organizational units are departments, divisions, sections, branches, groups, project teams, job families or similar units.
For each organizational unit, the following must be included:
name of the unit;
job title, gender, race and ethnicity of the supervisor;
total number of male and female incumbents;
total number of male and female incumbents broken down by Black, Hispanic,
|
|
|
|
|
|
|
|
|
|
|
Asian, and American Indian.
The regulations allow the use of the familiar Workforce Analysis in place of the Organizational Profile, so initially it is anticipated that most companies will choose to continue to produce the Workforce Analysis.
The required narrative elements have been narrowed, but increased emphasis has been placed upon the actual actions taken by the contractor. It is now more important than ever to customize the narrative for your company and not use simple "boilerplate" language. The required narrative elements are:
Designation of responsibility: This individual must have the authority, resources, support of and access to top management to ensure effective implementation of the affirmative action plan. In the comments section, the OFCCP recommends that an executive be assigned as director of equal opportunity programs.
Identification of problem areas: An in-depth analysis that includes an evaluation of the workforce by organizational unit and job group, all personnel activity, compensation systems, and personnel procedures.
Action-oriented programs: The contractor must ensure that these consist of more than just following the same procedures which have previously produced inadequate results.
Internal audit: Key elements include: monitoring personnel records, requiring internal reporting on a scheduled basis, reviewing the results with all levels of management, advising top management of the effectiveness of the plan and suggestions for improvement.
The new affirmative action regulations represent the broadest changes in affirmative action over the past 20 years. If past experience holds true, it will be several months or years before we know exactly how the OFCCP will actually enforce and interpret the regulations. Welcome to the 21st Century!
|
|
|
|
|
|
|
