Q. What goes into an Affirmative Action plan?
A. In reality, covered contractors will have three affirmative action plans, one each under Executive Order 11246, Section 503, and the VEVRAA or the JVA. Although plans are typically combined, the plan requirements are distinct.
Executive Order 11246:
– There are two general components of an Executive Order 11246 Plan: statistical analysis and narratives. The statistical components require a contractor to analyze employment data and personnel activity for the preceding 12 months for utilization of race, gender and ethnic groups, barriers to EEO, and statistically significant indicia of discrimination. The statistical reports include a Workforce Analysis or Organizational Profile (race/gender makeup of workforce by department); Job Group Analysis (race/gender makeup of workforce by Job Group); Availability Analysis (race/gender makeup of labor pools); Utilization Summary (race/gender utilization as compared to labor pools); Placement Goals (to address underutilization); Impact Ratio Analyses (statistical analysis of applications, hires, promotions and terminations); and Compensation Analysis.
– The statistical analysis, in large part, drives what remedial steps a contractor must take to address any issues, which are described in the narratives section. Among a laundry list of required actions, the contractor agrees to undertake an annual analysis of its personnel and recruiting practices for barriers to EEO and to hone its recruitment and outreach efforts as necessary to progress towards a diverse workforce. A sample, and very basic, Executive Order AAP can be found at: http://www.dol.gov/ofccp/regs/compliance/pdf/sampleaap.pdf