Affirmative Action Planning Five Common Mistakes to Avoid with your AAP Development

Press Release from Berkshire

Often, in the urgency to complete your AAP - whether for an audit, certification, or for presentations to leadership - the focus is to just get the placement goals and goal attainment results. But how can you make your plan even better and more effective? Here are five common mistakes you might be making in this rush and questions to ask when developing your AAP to ensure you develop a compliant plan.

  1. Analyzing incorrect data

    The first step is to ensure the correct data is getting pulled from your HRIS. A few questions to ask:

    - Are the personnel records accurate as of the effective date of the activity or as of the current date? A new hire may have since had a title change due to a promotion or reorganization, but in your Hires analysis, you want to analyze the activity related to the hire and not what happened afterwards.
    - Are the terminations true terminations, or are some only for payroll purposes? For example, if you process a termination to end employment and then a second termination when benefits end, your data pull may have included both actions thereby counting a single termination twice.
    - Are the promotions aligned with how your company defines a promotion? Does your company have action codes that differentiate promotions from lateral movements, demotions, reorganizations, title changes, etc.?
    - If you included rehires in your Hires records, did they have to re-apply, or were they just accepted back? Are you including hires in your analysis where there was no selection due to recall rights?

    Applicant data is especially important to review and confirm. Do you use evergreen requisitions? If so, have you included the correct pool of applicants from the evergreen for each hire? Every applicant from the evergreen who was considered for the same position as the person hired should be included. Are you only including the applicants who meet the internet applicant definition in your analysis? Are you able to determine who meets the internet applicant definition based on the disposition codes that the recruiters used? (Which might get to a deeper question addressed later – have the recruiters had the appropriate training to use disposition codes consistently and as intended?)

    Even if you are a large organization with many selection decisions, sometimes it helps to take a step back and remember what the analysis is ultimately doing – identifying problem areas by looking at individual and specific selection decisions. With each selection decision – whether it is a positive selection (hire, promotion) or negative selection (involuntary termination, demotion) –  is this a selection decision made by the company and have you included the correct pool of people – those who were also considered for the same selection?

  2. Using an outdated plan/job group structure

    Similar to making sure you are analyzing the correct data, you want to ensure you are analyzing it in the way that makes the most sense to your organization. While the regulations have specific guidelines for establishment based-plans, if your organization doesn’t necessarily fall into this cookie-cutter structure, the guidelines are a little more grey. Especially over the past couple of years, organizations have changed, so it might also be time to change the way you’re organizing your AAP. Do you have a large number of employees who no longer work at a physical establishment? You have several options for where to report them. If you opted to roll them into the AAP where the personnel function sits and that location is your headquarters, is your headquarters plan now very large? If your AAP structure has changed, does your job group structure still make the most sense? Do the jobs in the job groups make sense to analyze together (are they similar in content, opportunity, and/or wages)? Are the job groups now extra-large or perhaps too small? You may want to consider a job group structure revision and possibly different job group structures based on the plan. For example, your warehouse facility might have a different job group structure than your headquarters office as the jobs in each establishment may be very different. It might also be time to consider a Functional Affirmative Action Plan. Again, take a step back and remember the benefits of a properly developed AAP: identification of underutilized areas and potential problem areas in selection decisions. Is your AAP structured to realize those benefits and when you communicate the results to management, will they be meaningful? If the decisions about remote IT positions are included in the AAP for a manufacturing facility because they used to be physically on site, but management for IT is now located somewhere else, does it still make sense to include remote IT in the same AAP as before? If not, it may be time to reevaluate the AAP structure.

    Remember, if you are adjusting how the AAPs are organized, you will want to review the availability settings to make appropriate adjustments under the new structure. For example, if you now have a large number of employees who are remote, your reasonable recruitment area may need adjusted to account for the entire US population. Or, if you have moved employees to a different AAP, your feeder jobs and factor weights may have changed.

  3. Failing to document outreach efforts and tell your “story”

    Some of us might be more comfortable with data and numbers, focusing on the analysis and reports. But that doesn’t always tell the entire story. Whether or not you have placement goals or problem areas, the narrative is your chance to shine a light on your company and all the good faith efforts you are making. Rather than using boilerplate narrative language, make the effort to highlight the specific activities your company takes as part of your affirmative action program. Make sure you are documenting your outreach efforts and don’t forget to evaluate the effectiveness of those efforts. Get feedback from those who interact with these sources. Analyze how many candidates come from the agencies or vendors you work with and whether they are qualified for roles in your organization. Have your internal development programs been effective at preparing employees for promotion? Also, think outside the box – what other company initiatives might apply to your action-oriented programs?

    By taking the steps to evaluate your outreach efforts as part of your AAP development, you can identify which activities have been most useful and which activities, if any, are taking effort but not providing positive outcomes.

  4. Neglecting to communicate and train recruiters, hiring managers, and other key individuals

    Once the AAP is developed, what are you doing with it? Be sure that key participants and interested parties are aware of the results, trained on what the results mean, and understand their role in the affirmative action program. If you have placement goals, it is important to not only communicate these goals to the recruiters and hiring managers, but also ensure they understand what the goals  mean : that targeted outreach must be conducted and documented, and the most qualified individuals are still selected – that preferential treatment is not allowed. As mentioned above, if there are issues with your applicant data (which there always are!), make certain that recruiters understand the implications of their documentations (or failure to document). Inform those making the selection decisions that they must be done fairly and equitably, based on job related-criteria. And finally, if there are problem areas identified, make sure that the appropriate leaders are made aware so you can have their support in making improvements as needed. Affirmative Action Programs are not a one person job - change requires the support and effort of many within the organization!

  5. Overlooking the fine details of the AAP

    Especially for large organizations, the amount of data can be overwhelming. Leaders want the high-level overview of the placement goals and goal attainment. However, there are a lot of other aspects of the AAP that are just as important and shouldn’t be ignored or overlooked. As mentioned in #3, sometimes the numbers alone don’t accurately reflect the entire story.

    Just like ensuring that the job group and utilization analysis is accurate and appropriate, the workforce analysis should also be reviewed. This report should accurately reflect the staffing patterns within the establishment or function. What the OFCCP calls a “department” or “organizational unit” might be called something different in your organization, like “cost center” or “business unit.” This grouping would ideally also show lines of progression within the organization. Whatever you call it, be sure to organize the workforce appropriately so that you can identify if there is an area where minorities or women are underrepresented or concentrated. 

    Another question to ask is: how might the company’s culture be affecting the AAP analysis? If you have a low response rate for self-identification, is there a cultural change that might help? Voluntary terminations might not be a focus of analysis since it isn’t a company decision, but is there a company culture that adversely encourages certain groups to voluntarily leave? Is there a pattern of certain groups being promoted more than others? 

    And don’t forget to evaluate your processes. Beyond looking at cultural reasons for low self-identification response rates, consider the processes in place by which the information is requested. Sometimes a reconfiguration of systems and/or the process to request self-identification can make a significant difference in the response rates and therefore impact the quality and accuracy of your AAP analyses. 

    Digging into the details might bring to light something that could be addressed.

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