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affirmative action requirements 

Labor Relations Consultants

Updated on Oct 2, 2018

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AAP Consulting

AAP consulting is the prime service offered by us. First Advantage Consulting Firm (FACF) is a trusted AAP consulting agency providing comprehensive Affirmative Action Plan Consultants and AAP compliance requirement services to various organizations and industries especially in USA. We provide superior affirmative action compliance and OFCCP reporting consulting services. However, we are best known for affirmative action planning, consulting, training and affirmative action compliance programs to the Human Resources community throughout the United States and Puerto Rico. FACF is the industry leader in affirmative action plan outsourcing.

Hire your Affirmative Action Plan Consultants Today!

We welcome those companies desiring to hire us for their AAP preparation. Our qualified AAP consultants have mastered the latest policy and regulations of OFCCP regulations, ensuring that you receive a 100% fully compliant, totally defensible AAP. Affirmative Action Plan preparation is an arduous undertaking. The OFCCP has calculated that small businesses spend over 180 hours on their first AAP preparation and, for larger businesses, that number increases to well over 360 hours. In addition to the time consumed by such preparation, a certain amount of proficiency and knowledge is required. First Advantage Consulting Firm can take that burden off your shoulders and help your company by developing and implementing your AAP. Our staff is comprised of former OFCCP Senior Compliance Officers.
Who needs AAP Consulting?

Federal contractors and subcontractors with 50 employees and $50,000 in government contracts are required to develop, implement and maintain AAP’s while providing goods and services to the federal government.
Why you need it?

Affirmative Action Plans (AAP’s) are required to satisfy the equal-employment opportunity/affirmative action responsibilities for minorities and women under Executive Order 11246, as amended; people with disabilities under section 503 of the 1973 Rehabilitation Act; and covered veterans under the Vietnam Era Veterans’ Readjustment Act of 1973.

If your Government bills of lading totaling $50,000 or more in 12 months aggerates. In many cases, companies are required to implement an Affirmative Action Plan without a direct government contract. If government contractors purchase at least $50,000 worth of goods to fulfill their obligations on a government contract, then the goods’ seller is also subject to the OFFCP’s laws.

A gas station takes a government issued credit card. A hotel takes a government credit card are just some prime examples. A company furnishes a widget to a prime contractor who has a government contract. Even though there’s no direct contract with the government the company, if it exceeds $50,000 total revenue on those deals, then both sides must comply with Affirmative Action law.

Depository of government funds

Any financial institution, employing at least 50 people, with federal share and deposit insurance (including FDIC) is considered to be a government contractor, and therefore fall under Affirmative Action ordinances. This covers nearly every bank in the United States.
How we are going to help you?

We develop and Implement an Affirmative Action Plan that is cloud-based and containsa narrative and statistical component. The narrative is a detailed description of the practices of an organization in support of the good faith efforts to protect women, minorities, veterans and disabled employees from discrimination in hiring practices both intentional and impactful. The statistical component includes the following analyses:

Workforce Analysis – listing of job titles in the organization classified into organizational units or work groups

Job Group Analysis – listing of each job title in the organization in terms of job groups and identifies the number of female and minority incumbents in each job group

Availability Analysis – determines the availability of women and minorities by considering a reasonable recruitment area and promotions possible in the organization

Utilization Analysis – compares incumbent women and minorities with available women and minorities and identifies areas of underutilization

Adverse Impact Analysis – determines the statistical indication of adverse (disparate) impact against a protected class and analyzes the HR flow in all aspects of employee selection, promotions and terminations

Placement goals must be set when the percentage of minorities or women in a job group is less than reasonably expected given their availability percentage in that job group. Placement goals equal the availability percentage and serve as targets that organizations can meet through good-faith efforts and action-oriented programs.

Compensation Data Analyzed

OFCCP has also suggested that contractors adopt this process to their internal analysis.

SSEGs
Initial Screening
Multiple Regression

The Need to Create Similarly-Situated Employee Groupings (SSEGs)

OFCCP has suggested to contractors to develop a new grouping method for compensation analysis. These groupings, are known as SSEGs, should combine employees with: Similar Work, Level of Responsibility, Skills and Qualifications.

SSEGs should have at the minimum of 30 employees, and have at least five of whom should be minorities or females.

Initial Screening for Potential Discrimination

The initial screening for potential discrimination consists of comparing average salaries of minorities and non-minorities, females and males. A 5% difference in mean salary is a positive indicator that discrimination may exist and shows a potential need to use Multiple Regression Analysis.

Although this definition sounds very similar to the definition of an AAP Job Group, the OFCCP has stated that Job Groups may not be suitable for use as SSEGs. An example of this cited by the OFCCP would be two employees having identical job titles but very different levels of responsibility.

Multiple Regression Analysis to Statistically Validate Discrimination

Regression analysis involves identifying all of the independent variables that may affect salary (such as tenure, performance appraisals, education, etc.). A regression analysis should be performed on each of these variables to see if it explains the differences in pay. If disparities in compensation cannot be explained through regression analysis, then the contractor should document its findings and, if necessary, take action to remedy the situation. For many HR and Compensation analysts, multiple regression analysis is a highly complex statistical process that usually necessitates the use of specialized software or outside guidance.
Why you choose us?

We have over 110 years’ experience and expertise and is our passion. Our staff consists of all former or retired OFCCP Sr. Compliance Officers. We are all inclusive and offer an industry leading “OFCCP Mock Desk Audit” we use the methodology as OFCCP.
Our work process?

We will be with you every step of the way we will require two spreadsheets to be filled out. The data will come from you Applicant Tracking System and your HRIS system. If you do have such we will send you an Applicant flow log and work with you in retrieving the data.

We will send you an New Client On-Boarding Handbook that will explain all the process and explains what to expect from those requirements. We are all inclusive and provided 24/7 support.

Basic Requirements / check list
Required for Initial Submission (Compulsory)

Employee data for the required period including compensation as of 1st day of new AAP year
Applicant flow logs for the required period
EE0-1 reports for the last three years
VETS-100/100A report for most recent year
Assessment documents for outreach and recruitment efforts for Section 503 and 4212
Accommodation policies and logs
Any supporting documentation to show specific, targeted outreach efforts and action-oriented programs to meet unmet AAP goals (documentation of recruiting efforts specific to areas of underutilization in plan)
EEO Policy Statement indicating top US executive support
Union information
If you have a union, you will need a copy of the bargaining agreement and the name, address, and phone number of the union steward.

Nice to Have (Optional)

Postings with state employment service delivery system
Copy of online or newspaper ads showing EO tagline
List of places from which you recruit
Company overview including company logo or printed on letterhead
Copy of purchase order with affirmative action verbiage
Policies on maternity leave, FMLA leave, harassment
“EEO is the Law” poster for applicants and employees
E.O. 13496 poster (employee rights under Federal labor laws)
Online accessibility statement
Map

affirmative action requirements 

100 Galleria Parkway, Ste 1700, Atlanta GA 30339 100 Galleria Parkway, Ste 1700, Atlanta GA 30339 ATLANTA, GA 30339

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