HR Policies & Procedures

Writing or Auditing Your Affirmative Action Plan: Tough Jobs Made Easier

Writing or auditing your AAP makes filling out your IRS Form 1040 look tame. But there is a resource to help you do it better and easier.

The EEO-1 report recently written about in HR Daily Advisor is just one part of an effort by this nation to end discrimination in the workplace. It started with the Civil Rights Act of 1964 and has been expanded through numerous subsequent laws, regulations, and executive orders.

One key prong of this effort is Affirmative Action, which seeks to ensure that employers recruit and promote in a way that, over time, eventually makes their workforce mirror the ethnic and gender makeup of the applicant pool from which they hire.

To meet that goal, companies doing business with the federal government that meet a “50/50” threshold (50 or more employees, $50,000 or more in government contracts), and their subcontractors, must, by law, prepare a detailed Affirmative Action Plan (AAP). The plan is subject to audit by the Office of Federal Contract Compliance Programs (OFCCP).

Anyone who’s done an AAP knows that filling out your annual IRS Form 1040 is a walk in the park by comparison. The company’s Equal Employment Opportunity Coordinator (often the HR person) needs to access reams of census data to determine job market characteristics, conduct internal surveys, do calculations and assure that myriad policies and procedures are in place.

No wonder so many make their best guess and hope no one will ever review what they’ve done. Trust us not a good idea. OFCCP can conduct an audit and threaten a contractor’s status. For a company that depends on government contracts for its livelihood, that’s a recipe for bankruptcy.

“The Most Usable Set of AAP Instructions…”

If you face these daunting tasks, you might want to look at a BLR publication called How to Write an Affirmative Action Plan. It’s very likely the most usable set of instructions you’ll ever find for doing an AAP … or for making sure the one you have is up to snuff.

The usability comes from the combination of writing in plain English and formatting the book to fit the way you actually work two talents that we’re convinced are part of our editors’ DNA.

One example of that practical formatting: The editors have included a complete, filled-out sample AAP as a series of two-page spreads. One page is from the plan. The facing page is a commentary on the plan page.
This makes it especially easy to understand what each part of the plan is looking for and how to fill it in correctly.

The 96-page sample plan section, much of which is prewritten material that’s ready to copy, modify, and use, makes up the heart of the book, but it’s just part of the book. You’ll also find:

–Background and rationale behind the EEO and affirmative action movements and the agencies that enforce them.

–Complete instructions and sample charts on how to do the required factor analysis.

–Instructions on how to do an AA self-audit, and how to prepare for an OFCCP audit.

–Summaries of federal and state discrimination and equal pay laws, as well as the full text of key federal regulations.

–Prewritten sample letters, policies, and postings for your applicants, employees, and subcontractors, each one easily modified to include your specifics.

We’ve seen our editors do some pretty thorough work, but this guide takes the prize for making a difficult task doable. In fact, it did take a prize. How to Write an Affirmative Action Plan won a Grand Award in a recent Awards for Publishing Excellence (APEX) competition which, for a publisher, is like winning the Best Picture Oscar in Hollywood.

If you have any Affirmative Action Plan needs, either to write one or check the one you’ve got, this just might be the resource you need.