The People for the Job
Setting up your AAPs
Conducting the Incumbency vs. Availability Analysis
Creating Placement Goals
Implementing your plan
 
1. The People for the Job
AAP creation and reporting is not a simple task. The person assigned to create a plan must have adequate experience or receive training. An alternative is to outsource plan creation. While EEO and Affirmative Action planning may not be your company's core competency, it is essential to perform these tasks well if your company is, or decides to become, a government contractor. Audits can be lengthy and costly.
 
2. Deciding how to set up your AAPs
Current regulations require a separate AAP for establishments with at least 50 employees with certain exceptions.
 
All domestic employees must be covered in an AAP:

Functional AAPs are allowed but require OFCCP approval. OFCCP still reserves the right to conduct compliance evaluations at the establishment level for functional AAPs.
 
3. Conducting the Incumbency vs. Availability Analysis
To determine whether the percentage of minorities or women is less than would reasonably be expected, you can select from among several different rules. Over the years, a number of mathematical rules (formulas) have been developed to measure the differences between incumbency and availability. These are:

4. Placement Goals (41 CFR 60-2.16)
If, following your calculations and AAP analyses, the percentage of minorities or women is less than would reasonably be expected, you will need to establish goals. Your goal should be equal to the availability percentage calculated in the Availability Analysis. For example, your goal might be to fill 12.1 % of openings in a job group with minorities or women (wherever the percentage of minorities or women is less than would be reasonably expected).
 
When goals have been set for job groups, your HR department will need to monitor progress, during the current AAP year, made towards goals.

For example, your goal is 23% minority employment. 15 hires and promotions have been made during the year, of which 5 were minorities. This equals 33.3%, and you are meeting your goal.
 
If your company is a federal contractor you will need to submit the following government filings by September 30th each year:

5. Basics for Plan Implementation
Once you have created a plan and set goals, you have all the information in place you will need. Your biggest challenge will be to implement your plan and gain internal plan acceptance.
 
One of the first and easiest steps you can take in plan implementation is to invite job applicants to self-identify with regard to race, ethnicity and sex status. This will help communicate your policies and make the data collection for your annual AAP easier. If your company has 150 or more employees and a $150,000 federal contract or subcontract, you will need to track personnel activity (applicant flow, hires, promotions, etc.) by race and gender for a minimum of two years. If you have less than 150 employees or your contract is for less than $150,000, the data needs to be maintained for a year.
 
Communication is one of the most important aspects of plan implementation. Compliance Officers will look for AAP/EEO notices and posters through out your building, and check your job ads, as well. Communicating how hiring procedures are impacted by your affirmative action plan to hiring managers will get everyone on board with company AAP objectives. This will make hitting your goals easier in the long run. Department, staff meetings, and one-on-one meetings, can help get the word out about your company's AAP obligations to recruit and hire minorities, women, people with disabilities, and covered veterans.
 
Beyond communications with hiring managers, you will need to convey to senior management the importance of the company's EEO AAP obligations; this should probably take the form of a focused presentation.
 
Finally, you must communicate your company's EEO policy to vendors and subcontractors as per government regulations. Communicating your policies to employment resources and community groups can help with recruiting and community relations.
 
Good ways to ensure that everyone is clear on your EEO policy include:

Talking to your community and having a well-prepared AAP, should you be audited, are among the best ways to communicate your policies externally, which can result in positive PR. You might also consider listing open positions with your local State Employment service, or America's Job Bank.
 
Besides tracking personnel activities, you should also keep a record of all relevant good faith efforts (i.e. job postings), and keep records of EEO-1 and VETS-100 filings. Good record keeping is the easiest way to avoid an unpleasant audit experience.