Understanding and Preparing an Effective AAP Narrative
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Contact Information
Dao Nguyen [email protected]
Oscar Martinez [email protected]
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Overview of Biddle Consulting Group
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Affirmative Action Plan (AAP) Consulting and
Fulfillment
• Thousands of AAPs developed each year • Audit and compliance assistance • AutoAAP™ Enterprise software
HR Assessments
• AutoGOJA™ online job analysis system • TVAP™ test validation & analysis program • CritiCall™ pre-employment testing for 911 operators • OPAC™ pre-employment testing for admin professionals • Video Situational Assessments (General and Nursing)
Custom Test Development & Validation
•“High stakes” test development •Validation studies in response/prevention to litigation
EEO Litigation Consulting /Expert Witness Services
• Over 200+ cases in EEO/AA (both plaintiff and defense) • Focus on disparate impact/validation cases
Compensation Analysis • Proactive and litigation/enforcement pay equity studies • COMPare™ compensation analysis software
Publications/Books • EEO Insight™: Leading EEO Compliance Journal • Adverse Impact (3rd ed.) / Compensation (1st ed.)
BCG Institute for Workforce Development
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Speaking and Training • Regular speakers on the national speaking circuit
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Background and Context
Review of Each Section in the Narrative
Managing the Narrative and Bolstering Action-Oriented Programs
In Conclusion: Summary, Questions, and Answers
Agenda
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Narratives for Affirmative Action Programs
Three (3) types of written Affirmative Action Programs:
1) AAP for Minorities & Women (E.O. 11246)
2) AAP for Individuals with Disabilities (Sec. 503 of the Rehabilitation Act)
3) AAP for Protected Veterans (VEVRAA)
Background and Context
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Ref: 41 CFR 60-2.1 (b) (1) (i-iv)
1) Narrative for Women and Minorities Executive Order (E.O.) 11246 Requires federal contractors to create an AAP (including
narrative) if they meet one of the following criteria:
• 50 or more employees and $50,000 or more in contract revenue during a 12 month period
• Serves as a depository of Government funds in any amount
• A financial institution who issues and pays U.S. saving bonds or saving notes
Background and Context
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2) Narrative for Individuals with Disabilities Section 503 of the Rehabilitation Act of 1974,
as amended
50 or more employees and a contract of $50,000 or more
Ref: 41 CFR 60-741
Background and Context
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3) Narrative for Protected Veterans Vietnam Era Veterans' Readjustment
Assistance Act of 1974, as amended
• 50 or more employees and a contract of $150,000 entered into, or modified, on or after October 1, 2015
Covered contractors “shall take affirmative action to employ and advance in employment qualified protected veterans.”
• Disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans are considered “protected” under VEVRAA.
Ref: 41 CFR 60-300
Background and Context
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Thresholds
Individuals with
Disabilities
Women & Minorities
Protected Veterans
Contract Amount
Section 503 of Rehabilitation Act of 1973
Executive Order 11246
Vietnam Era Veterans' Readjustment Assistance Act of 1974
$50,000
$150,000
Background and Context
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Practice Tip: Confirm the amounts of federal contracts/subcontracts. It may be the case that you meet the requirements of E.O. 11246 and Sec. 503, but not VEVRAA.
Narrative Content for Women and Minorities
Explanatory chapters
• Chapters 1-6 (explain the technical reports) [Optional]
Designation of Responsibilities
• Who is responsible to implement the AAP
President CEO, HR Manager, AA Officer, Managers and Supervisors
Identification of Problem Areas
• Do impediments to EEO exist?
Action Oriented Programs
• The implementation portion of the AAP
Internal Audit and Reporting
• Measures the effectiveness of the AAP
Background and Context
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Narrative Content for Protected Veterans (Vets) and Individuals
with Disabilities (IWDs)
Background and Context
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Required Components Vets IWDs
1. Equal Opportunity Policy Statement √ √
2. Review of Personnel Processes √ √
3. Review of Physical and Mental Qualifications √ √
4. Reasonable Accommodations to Physical and Mental
Limitations
√ √
5. Commitment to Anti-Harassment √ √
6. External Dissemination of Policy, Outreach, and
Positive Recruitment
√ √
7. Internal Dissemination √ √
8. Audit and Reporting System √ √
9. Identification of Responsibility for Implementation √ √
10. Training √ √
11. Data Collection and Analysis Hiring
Benchmark
Utilization
Goal
12. Compensation √
√
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Background and Context
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Step 1: Availability Analysis
Identifies the gender and race composition of the available
workforce
Step 2: Comparison of Incumbency to Availability
Identifies differences between current incumbency and
available workforce
Step 3: Placement Goals
Calculates the goal needed to eliminate underutilization for
where differences exist
Step 4: Action-Oriented Programs
Affirmative steps that will be taken to help achieve
goals (outlined in narrative)
Overall “Big Picture”
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Review of Each Section
in the Narrative
Review of Each Section in the Narrative
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Chapter 1: Organizational Profile Chapter 2: Job Group Analysis Chapter 3: Placement of Incumbents in Job
Groups Chapter 4: Determining Availability Chapter 5: Comparing Incumbency to
Availability Chapter 6: Placement Goals
• Explanation of the technical reports • These chapters aren’t required
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Review of Each Section in the Narrative
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Chapter 7: Designation of Responsibility
• Required component • Stating who is responsible for the
implementation of the AAP • What are the commitments for upholding the
AAP? • Annually review/update the responsibilities
listed for each officer as necessary
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Review of Each Section in the Narrative
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Chapter 8: Identification of Problem Areas
• Required component • Derived from placement goals for women and
minorities • Identify which job groups/areas that posed a
concern
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Review of Each Section in the Narrative
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Chapter 9: Action-Oriented Programs
• Required component • OFCCP hotspot • “Good faith efforts” to remedy problem areas
from chapter 8 • Prepare a list of programs that your company
has implemented, planning to implement, and/or currently undertaking in order to achieve diversity in the workforce
• Annually review/update as necessary
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Review of Each Section in the Narrative
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Chapter 10: Internal Audit and Reporting
• Required component • Identify what your company is doing to uphold
chapter 9 • Periodically audit yourself internally • Document actions/steps for success
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Review of Each Section in the Narrative
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Chapter A: Policy Statement
• Required component • Company’s statement of commitment to uphold
Affirmative Action and Equal Employment Opportunity for all
• Must show the U.S. top executive’s full support • Recommended to have U.S. top executive's
signature • Annually reviewed/updated as necessary
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Review of Each Section in the Narrative
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Chapter B: Review of Personnel Processes Chapter C: Physical and Mental Qualifications Chapter D: Reasonable Accommodation to
Physical and Mental Limitations Chapter E: Harassment
• Required components • Annually reviewed/updated as necessary
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Review of Each Section in the Narrative
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Chapter F: External Dissemination of Policy, Outreach, and Positive Recruitment
• Required component • OFCCP hotspot • “Good faith efforts” to positively recruit to
protected veterans and individuals with disabilities
• Prepare a list of programs that your company has implemented, planning to implement, and/or currently undertaking in order to achieve diversity in the workforce
• Annually review/update as necessary
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Review of Each Section in the Narrative
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Chapter G: Internal Dissemination of Policy Chapter H: Audit and Reporting System
• Required components • Annually reviewed/updated as necessary
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Review of Each Section in the Narrative
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Chapter I: Responsibility for Implementation
• Required component • Stating who is responsible for the
implementation of the AAP • What are the commitments for upholding
the AAP? • Annually review/update the responsibilities
listed for each officer as necessary
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Review of Each Section in the Narrative
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Chapter J: Training Chapter K: Data Collection Analysis Chapter L: Compensation
• Required component • Annually review/update as necessary
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Managing the Narrative and Bolstering Action-Oriented Programs
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• Use a word document that cites the reports as appendices/exhibits
• Narrative prior to reports
Pros and cons?
• Narrative separated and included with the reports Pros and cons?
• Larger companies vs. smaller companies
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Managing the Narrative and Bolstering Action-Oriented Programs
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• Think outside of the box and DOCUMENT!
• Document and emphasize ALL good faith efforts
• Utilize diverse recruitment agencies
• Advertize in publications
• Attend all local diversity career/job fairs
• Get involved in your community
Hold events to raise money that provides services to ensure that children/adults with disabilities have equal opportunities to live, learn, work, and play
Hold career shadow days to middle/high school students
• Publish in-house recruiting brochures where minority, female, protected veteran, and/or disabled members of the workforce are included
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Managing the Narrative and Bolstering Action-Oriented Programs
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• Utilize the following organizations that provide services to women and minorities:
American Association of University Women Asian Women’s Self Help Association Dress for Success – Washington, DC Alexandria JobLink Job Corps Center Regional Chambers of Commerce Year Up Transitional Housing BARN, Inc. (BARN)
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Managing the Narrative and Bolstering Action-Oriented Programs
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• Utilize the following organizations that provide services to protected veterans and individuals with disabilities:
Laurie Mitchell Employment Center ServiceSource Vocational Rehabilitation Department of Rehabilitative Services Military Veteran Centers American Women Veterans Disabled American Veterans Employer Partnership of the Armed Forces Army Career & Alumni Program Veterans Affairs Department Corporate Gray Sheridan Walker – HirePotential
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Managing the Narrative and Bolstering Action-Oriented Programs
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• Create mentoring programs Create an environment for employees to navigate paths to
connect, learn, and grow The mentee benefits from the program: enhancing the
employee’s understanding of the company, expanding their professional network, opportunities for accelerated learning, and exposure to a variety of career paths
• Encourage employees to actively participate in company-
sponsored social and recreational activities to improve attraction and retention of minority, female, protected veteran, disabled employees This encouragement comes in may forms including awards and
opportunities
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Managing the Narrative and Bolstering Action-Oriented Programs
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• Provide funding/grants to specialized organizations
geared towards women, minorities, protected veterans, and individuals with disabilities (if budget allows) Have fundraisers
• Initiate carpooling and van programs to drive employees (if budget allows for)
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Managing the Narrative and Bolstering Action-Oriented Programs
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BIG PICTURE You want to ensure that your policies foster an environment of
inclusion that’s free from barriers for all employees and applicants.
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Managing the Narrative and Bolstering Action-Oriented Programs
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OFCCP Resources
Employment Referral Resource Directory
(ERRD): https://ofccp.dol-esa.gov/errd/
https://www.dol.gov/ofccp/regs/compliance/resources_recruit_disa
bility.htm
https://www.dol.gov/ofccp/regs/compliance/resources_selfid.htm
https://www.dol.gov/ofccp/regs/compliance/resources_info.htm
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Managing the Narrative and Bolstering Action-Oriented Programs
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Veteran Outreach Programs
www.vetjobs.com
www.hirepatriots.com
www.veterans.jobs
www.veteransoutreach.com
Disability and Veterans Community Resources Directory: https://ofccp.dol-esa.gov/errd/entiredirectoryform.html
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Managing the Narrative and Bolstering Action-Oriented Programs
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Disability Outreach Programs
www.viscardicenter.org/nbdc *FREE
www.abilitylinks.org *FREE
www.abilityjobs.com
www.gettinghired.com
www.projecthired.org
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In Conclusion
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Industry Updates
• Revised EEO-1 Reports
New requirements to report W-2 compensation data and hours
worked (On hold pending review)
File as before, but by new March 31st, 2018 deadline
• Proposed OFCCP Merger with EEOC
White House budget indicated merger
Large resistance by federal contractors, OFCCP and EEOC, equal
rights organizations, etc.
On September 7th, 2017, Senate Appropriations Committee’s
spending bill eliminated the merger
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Industry Updates • VETS-4212 Reporting
Date parameters remain the same – “snapshot” employee data
from any payroll period between July 1 – August 31, 2017, and
hires data for 12-month period prior to that selected payroll
period.
Deadline is currently September 30, 2017
Unclear whether the VETS department will adjust the reporting
requirements to align with the new EEO-1
Filing extension until November 15, 2017 for hurricane relief
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Upcoming Webinars
September 29 – EEO1
October 19 – OFCCP Audit 101 and Common
Audit Questions
October 26 – Disparity Analysis 101
November 2-3 – AAP Boot Camp
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Visit bcginstitute.org to register!
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Q & A
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