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In depth affirmative action 3

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Some specifics:

Page 37, Desk Audit \ 22

b. Section 503 and Section 4212 (or VEVRAA) AAPs. If one or more of the below listed Section 503 and Section 4212 AAP elements is missing, COs automatically consider the submission unacceptable.

Equal employment opportunity policy statement

Review of personnel process to ensure full consideration of individuals with disabilities and protected veterans for available opportunities.

Review of physical and mental job qualifications to ensure they are job-related and consistent with business necessity

Reasonable accommodation policy

Harassment policy

External dissemination of contractor’s EEO policy

Internal dissemination of contractor’s EEO policy

Description of the contractor’s audit and reporting system

Identification of the person(s) responsible for implementation of the AAP

Training policy..for all personnel involved in the recruitment, screening.. to ensure that the commitments in the contractor’s AAP are implemented

Page 45, Desk Audit \ 30

c. Action Oriented Programs. 41 CFR 60-2.17(c) requires that contractors develop and execute action oriented programs designed to correct problem areas and to attain established goals and objectives.

By “specific” we mean that the programs describe in some detail what action the contractor will take, who is responsible for taking the action, and when the action will be accomplished. “Result-oriented” programs are those where proper execution of the program will likely lead to an increase in minority and female participations, or both, in the department, job group, training program or other identified problem area. The action oriented programs must be sufficient, if successfully implemented, to achieve their stated objectives. Contractors must describe these programs in the AAP(s).

Page 49, Desk Audit / 34

1H Review of Section 503 and Section 4212 AAPs for acceptability.

1H00 Items Included

… to be acceptable, a contractor’s Section 503 and Section 4212 AAPs must include the below items listed in 41 CFR 60-741.44(a) through (j), and or 60-300.44(a) through (j),

The FCCM sates on

Page 56-57, Desk Audit / 41

1L Analysis of the EO 11246 AAP: Goals Progress and Good Faith Efforts

The effectiveness of a contractor’s overall affirmative action program is not measured by whether the contractor met all its goals, but rather by whether the contractor made good faith efforts to do so.

1L00 Analysis of Goals Progress

….to be acceptable, AAP support data must include a report of progress on prior AAP year goals.

b. Analysis. …. More specifically, to determine how many minorities or women the contractor would have placed if the goal were met.

1L01 Evaluation of Good Faith Efforts

An evaluation of good faith efforts includes a review of the contractor’s overall performance toward goals, .. …and ensuring that adequate information is available to determine good faith efforts

http://www.dol.gov/compliance/laws/comp-vevraa.htm in the top part you see the words Record Keeping

Go there to find out more about VEVRAA.. http://www.dol.gov/compliance/guide/vietvets.htm

REFERENCE Link for Affirmative Action Department of Labor: http://www.dol.gov/compliance/laws/comp-eeo.htm

Shorter version:

The DOL / OFCCP requires covered government contractors and subcontractors to:

  • Implement written affirmative action plans for veterans and disabled individuals that include a goal of hiring/employing disabled employees at the rate of at least 7% of the workforce, and hiring veterans at the rate of at least 8%, or the contractor’s own benchmark for veterans based on available data;
  • Invite applicants and employees to self-identify as being disabled and/or covered veterans at the time of application, after receiving a job offer, and every five years for disability status.  This will require contractors and subcontractors to revise their pre-employment self-identification forms to include disability and veteran status, and to update their application flow logs to include tracking by these categories.  Under existing OFCCP practice, it is critical that a contractor identify each position that an applicant applied and was considered for;
  • Collect and annually review/audit data on the number of applicants who have self-identified as being disabled or a covered veteran, the total number of job openings and jobs filled, the total number of applicants for all jobs, the number of veterans and disabled individuals hired, and the total number of applicants hired.  This data must be retained for three years.  Note that in the case of an OFCCP audit, contractors and subcontractors that have not gathered the required applicant data will be unable to recreate this data at that time; 
  • Include new bold print language in covered subcontracts alerting the subcontractor of its affirmative action and non-discrimination obligations;
  • Identify and link with recruitment sources dedicated to providing job opportunities to veterans and the disabled, assure that all job openings are made available to qualified veterans and the disabled, and provide state and local job services with all job openings for positions other than senior management with a notice (i) that it is a federal contractor/subcontractor, (ii) that it desires priority referrals of veterans for all openings, and (iii) providing the name, location, and contact information for the responsible person for hiring at all locations in that state; and
  • Identify, upon request from the OFCCP, all formats in which affirmative action records are kept so that the OFCCP can decide which format it prefers, and make those records available off site if requested by the OFCCP.

The requirement to develop a written affirmative action plan applies to all entities (with 50 or more employees) that contract with the federal government for the purchase, sale or use of personal property or non-personal services (including construction) in excess of $50,000 (for purposes of disability affirmative action), $50,000 (for purposes of veterans affirmative action if the contract was entered before December 1, 2003), and $100,000 (for purposes of veterans affirmative action if the contract was entered or modified after December 1, 2003).

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