For several years, federal government contractors with 50 or more employees and government contracts of $50,000 or more have been required to develop written Affirmative Action Plans (AAPs) for each of their establishments with 50 or more employees. This two-part series will provide insight into the plan development process as well as tips to increase the likelihood of prevailing unscathed (or at least within tolerances) in the event of a government audit.
AAP Plan Development: Streamlining the Process
Depending on the size and complexity of an organization, AAPs may require tens or hundreds of hours development time to ensure they meet their exacting requirements. And while the outsourcing and software options available today reduce the Herculean task to manageable proportions, there is nothing that will completely eliminate the task of plan development from your employee workload. With that being said, there are several effective strategies that can help reduce the effort required each year.
- Develop your outsource plan.
Outsourcing agencies have dropped their prices to the point where it has become a viable option for most organizations.
Having professionals develop your plan will:
- reduce exposure
- ensure compliance with ever-changing regulations
- ensure the plans display your organization in the best light
- free your workforce to do what they were originally hired to do
It may even save your organization money if you factor in the amount of time your employees will spend on the project and/or the potential for negative audit results due to a lack of regulatory knowledge and defense strategies.
- Use software if outsourcing is not an option.
For those organizations without the means to outsource their plans, or who would rather complete them in house, software is an absolute necessity. And while software is no panacea (all AAP software systems require data preparation and a knowledge of AAP principles), Biddle Consulting Group’s AutoAAP® system has proven to be a robust program supported by a team of high-quality experts.
- Stick with it.
AAP’s require nearly twice as much time to develop in the first year as in subsequent years. Data protocols are established in the first year and narrative modifications can take time. In subsequent years, only minor modifications are necessary to the narrative and, ideally, data is easier to create having completed the task in the previous year.
- Continuously update your data.
AAPs require collecting and analyzing transaction data (i.e., hires, promotions, terminations, and yes, applicants). In order to minimize the task of collecting this data in subsequent years it is recommended that protocols be established to either collect this information as it occurs (i.e., in spread- sheets) or track it in some type of HRIS system. The time spent now will return ten-fold when it comes time to again collect the necessary data.
In part 2 of this series, we’ll look at a few OFCCP audit tips for the savvy contractor.
In the meantime, if you have any questions, please let us know!
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