What is included in a plan?
What are the data elements?
Who is included in each AAP?
What are the statistical reports in an AAP?
 
1. What is included in an AAP?
Per AAP regulations , "an affirmative action program must include...quantitative analyses...and...components described in 60-2.17."
 
This translates to:
 
Quantitative reports such as Organizational Profile, Job Group Analysis, Availability Analysis, Incumbency v. Availability Analysis, and Goals, which are based on the employer's workforce as of a particular date (the snapshot date)
 
A written narrative detailing designation of responsibility for implementation of AAP, identification of problem areas, action-oriented programs, and periodic internal audits, as required under the latest regulations.
 
While not part of the AAP, additional data such as applicant flow must be collected and submitted to the OFCCP as part of a compliance evaluation.
 
2. What are the basic data elements for an AAP?
Internal to your organization
 
Employees in the contractor's workforce (as of the AAP date):

3. Who is included in each AAP?
Currently, employees should be included in the AAP at which they physically work except employees who work at an establishment other than that of the manager to whom they report, must be included in the AAP of their manager
 
Employees who work at an establishment where the contractor (your company) employs fewer than 50 employees, may be included under any of the following:
 

Employees for whom hiring decisions are made at a different establishment must be included in the AAP where the hiring decision is made (Corporate Initiative).
 
Annotation Requirement
If employees are not included in their work location AAP because of the company's requirements and/or choices made in 60-2.1 (d) (1) to (3), the contractor is required per 60-2.1 (e) to annotate both the Organizational Profile and Job Group Analysis.
 
For an AAP at which the employee works but is to be excluded, make annotations to indicate in which AAP the employee is included.
 
For an AAP in which the employee is included which is different than where the employee works, make annotations to indicate the employee's original work location AAP.
 
4. What are the statistical reports in an AAP?
Organizational Display
Work Force Analysis
Job Group Analysis
Availability Analysis
Incumbency v. Estimated Availability Analysis (including Goals)
 
The Organizational Display (41 CFR 60-2.11 (b))
This can be a detailed graphical or tabular chart, text, spreadsheet, or similar presentation of your company's organizational structure. You must include the names of organizational units; job title, gender, race, and ethnicity of each organizational unit supervisor; the total number of male and female incumbents; and the total number of male and female incumbents in each minority group.
 
The Work Force Analysis (41 CFR 60-2.11 (c))
This report aggregates employees by departments and job titles. You must calculate race and gender counts by job title within each department (how many white males, white females, black males, etc.). Order job titles within departments by compensation, from lowest to highest. This report is required as part of an AAP if you are not preparing the Organizational Display.
 
The Job Group Analysis (41 CFR 60-2.12 and 60-2.13)
This report aggregates employees by job groups and job titles. Job groups are sets of job titles that share similar content, wage rates and opportunities.
 

 
This analysis calculates race and gender counts by job title within each job group (men, females, minorities, etc.). You should order job titles within job group by compensation, from lowest to highest. Percentages of women and minorities in each job group must be noted.
 
When forming job groups you should consider separating job titles by:

 
The Availability Analysis (41 CFR 60-2.14)
AAP regulations require federal contractors to estimate the availability of women and minorities. In an Availability Analysis, you identify the various labor pools from which employees are selected, and map the pools to job groups. You will also need to estimate the proportion of females and minorities in each pool.
 
AAP regulations identify two standard pools from which employees are selected:
 

 
Value Weights
After calculating the availability for each factor, the next step is to assign value weights indicating the extent to which the job group draws employees from each factor (pool or source), or, alternatively, the extent to which each factor contributes employees to the job group.
 
Value weights applied in the Availability Analysis:

The Incumbency v. Estimated Availability Analysis (41 CFR 60-2.15)
You will need to compare the representation of minorities and females in your work force to the availability estimate calculated in the Availability Analysis. This should be calculated on a per job group basis.
 
If the work force representation is less than availability, you will need to determine whether the percentage of minorities or women is less than would reasonably be expected.
 
Remember that:

The final component to your AAP is the AAP Narrative.
 
AAP Narrative (41 CFR 60-2.17)
The AAP Narrative, which supplements the quantitative analyses described above, has four required sections: