Affirmative Action Planning

Affirmative Action Plans: What You Need to Know (Part 2)

This is the second in the two-part series Affirmative Action Plans: What You Need to Know. Last week we looked at ways to streamline the AAP development process. Today’s post will share tips to increase the likelihood of prevailing unscathed (or at least within tolerances) in the event of a government audit.

Audit Tips for Savvy Federal Contractor

The Office of Federal Contract Compliance Programs (OFCCP) has increased the number of audits it conducts by implementing shorter (sometimes as short as 15-20 minutes) audits called “desk audits.” If everything is satisfactory in a desk audit, the proceedings do not grow into a potentially more costly and time-consuming on-site or off-site audit. The goal of any organization is to provide the OFCCP with enough satisfactory information to get a representative to leave after the desk audit. To this end the following tips have been provided:

  • Prepare a professional/professional-looking plan. 

Although this may seem superficial, the number one way to increase your organization’s odds of ending the audit with the desk audit is to provide the OFCCP with a professional, and professional-looking, AAP. It shows the auditor that your organization takes its responsibilities seriously. It also helps if the plan itself is dust-free and appears to have been “used.”

  • Analyze your data prior to the OFCCP.

Much like regularly scheduled check ups can help to protect against disease, regular evaluations of your organization’s hiring, promotional, termination, and compensation practices can help to avoid costly litigation and/or conciliation agreements. These types of analyses become even more important in tougher economic times when large class-action lawsuits proliferate due to lay-offs.

  • Prepare an action plan for any/all audits.

If your organization has prepared a professional plan, ensured its data is accurate, and analyzed the data to know in advance what the OFCCP will see, then all that’s left is to develop an audit strategy. Should your organization adopt a hard stance? If the OFCCP presses a conciliation agreement, should your organization fight or would it be cheaper and easier to concede? What precedent is set if your organization concedes? These and many other considerations should be discussed prior to the audit.

As always, if you have any questions about the above OFCCP audit tips or the AAP development process, please let us know. Also, be sure to check out the affirmative action planning webinars and resources at  – our online HR EEO training community.

[Read part 1 of Affirmative Action Planning: What You Need to Know]

Affirmative Action Plans: What You Need to Know (Part 1)

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:

  1. reduce  exposure
  2. ensure  compliance with ever-changing  regulations
  3. ensure the plans display your organization  in the best  light
  4. 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!

John Piatt, EEO/AA Director - Outreach & Customer Relations John Piatt
800-999-0438, ext. 118
Nancy Owen-Tipton, Account Executive Nancy Tipton
800-999-0438, ext. 175


So You’ve Completed Your AAP…What’s Next? (BCGi Webinar)

Heather Patchell, M.A., BCGi Director

Heather Patchell, M.A., BCGi Director

This Thursday, July 19th, Biddle Consulting Group’s Marife (Fe) Ramos and Jeff Davies will present the free BCGi webinar “So You’ve Completed Your AAP…What’s Next?

Heather Patchell, BCGi’s Director, interviewed Jeff recently about the upcoming webinar. During the brief interview, Jeff shared about the webinar’s topic, a bit about himself and how to get the most out of the training.

Are you wondering if this July 19th webinar is for you? Click “play” to find out:
(note: If you are unable to play the audio below, please download it.) 

[haiku url=”HP-JD-Interview-7-10-12.mp3″ title=”Pre-Webinar Interview: So You’ve Completed Your AAP…What’s Next?”]

Webinar Topic:

Now that you have completed your Affirmation Action Plans (AAP), do you know what the next steps are that you and your organization need to take? How are you supposed to ‘implement’ an AAP in order to fully benefit from the analysis results it conveys? Who should know about your AAP goals? This webinar will provide guidelines on how to review, plan, and implement your Affirmative Action Plans. Attendees will hear about tried and tested “best practices” that can be used for successful affirmative action planning and implementation.

Join Heather, Fe and Jeff on July 19th at 10:00 a.m. Pacific/1:00 Eastern for
So You’ve Completed Your AAP…What’s Next?

Fe Ramos & Jeff Davies of Biddle Consulting Group

Fe Ramos & Jeff Davies, Affirmative Action Planning Experts at Biddle Consulting Group

To register for this free July 19th webinar, please click the link below:

So You’ve Completed Your AAP…What’s Next?