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Affirmative Action Plans

Affirmative Action Plan Requirement

Executive Order 11246 requires all contractors and subcontractors with a federal contract of $50,000 or more, and 50 or more employees, to develop a written affirmative action plan (“AAP”).

For such employers, developing, maintaining, and applying an affirmative action plan is a critical element of equal employment opportunity (“EEO”) law compliance.

OFCCP Enforcement of Affirmative Action Plan Requirement

The Office of Federal Contract Compliance Programs (“OFCCP”) enforces the affirmative action plan requirement, and monitors government contractor and subcontractor compliance with nondiscrimination laws.

Preparing an affirmative action plan involves an in-depth analysis of the total employment process to identify any impediments to equal employment opportunity.

At a minimum, the employer must evaluate its workforce by organizational unit and job group to determine whether there are problems with the utilization or distribution of women and minority employees.

Each affirmative action plan must include the following:

  • Work force analysis. List of job titles by department, with number of employees by gender and race, along with salary range for each job group.
  • Job group analysis. List of jobs with similar content, wage rates, and opportunities, combined to form job groups.
  • Utilization analysis. Percentage of minorities and women in each job group.
  • Availability analysis. Availability of women and minorities in the relevant workforce.
  • Reasonable recruitment area. For each job group, with a brief explanation of the rationale for selecting that area.
  • Placement goals. When the percentage of minorities and women employed in a particular job group is less than would reasonably be expected given their availability, the employer must establish a placement goal.

How We Can Help

The attorneys of Harris Dowell Fisher & Young, L.C., provide services in connection with affirmative action plans, including preparing and reviewing such plans and responding to OFCCP compliance activities.

Contact us to discuss how we may best assist you in this regard.

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