Background - Affirmative
Action Compliance and Enforcement
•
Overview of Nondiscrimination
and Affirmative Action Compliance Requirements
•
Diversity and Its Relationship
to EEO and Affirmative Action
•
How and by Which Agencies
Compliance Is Enforced
•
OFCCP's Jurisdiction and
Current Enforcement Strategy
Preparing
To Develop the AAP
•
Determining Which Employees
Should Be Covered by an AAP
•
Employee and Transactions
Data Required for AAP Development
•
Determining and/or Changing
Your AAP Cycle
•
Determining and/or Changing
Your AAP Structure
Developing, Using, and
Defending the Organizational Profile
•
What the Organizational
Profile Is and How It Should Be Used
•
Preparing an Organizational
Display or Workforce Analysis
•
How OFCCP Evaluates the
Organizational Profile During Compliance Evaluations
Forming and Justifying
AAP Job Groups
•
What Job Groups Are and
How They Are Used Throughout the AAP
•
Job Groups and Their Relationship
to EEO-1 Job Categories
•
Principles To Keep in Mind
When Forming Job Groups
•
Preparing and Using the
Job Group Analysis
•
Complying With the Job
Group Annotation Requirement
•
How OFCCP Evaluates Job
Groups During Compliance Evaluations
4:30
p.m.
Wrap-Up and Questions
*There will be a 15-minute
break in the morning and afternoon and lunch served between
12:00 p.m. and 1:00 p.m.
Day
2
8:00
a.m.
Continental Breakfast
8:30
a.m.
Understanding and Calculating
Availability
•
Availability Defined
•
The Important Role Availability
Plays in the AAP
•
Determining Availability
by Individual Race/Ethnicity Groups
•
Availability
Data Sources and How Each Can Most Effectively Be Used
•
Determining Appropriate
Occupational Benchmarks
•
Determining Appropriate
Recruitment Areas
•
Estimating and Using External
Availability
•
Estimating and Using Internal
Availability
•
Calculating Final Availability
•
How OFCCP Evaluates Contractor
Availability Determinations
Comparing
Incumbency to Availability
•
Understanding the Process
That Leads to Placement Rate Goals
•
OFCCP's Four
Accepted Methods for Comparing Incumbency to Availability,
and the Advantages and Disadvantages of Each (80% Test,
Any Difference Test, Whole
Person Test, and Tests of Statistical Significance)
Affirmative Action Placement
Rate Goals
•
What a Placement Rate Goal
Is and How It Should (and Should Not) Be Used
•
OFCCP's Authority To Require
Goals for Individual Race/Ethnicity Groups
Executive Order 11246
AAP Narative Requirements
•
What Should and Should
Not Be Included in an AAP Narrative
•
Assigning Responsibility
for AAP Implementation
•
Identifying
AAP Problem Areas
•
Developing
and Executing Action-Oriented Programs
•
Developing and Implementing
Audit and Reporting Systems
Disability and Veterans
AAP Requirements
Strategies for Implementing
the AAP
4:30
p.m.
Wrap-Up and Questions
*There will
be a 15-minute break in the morning and afternoon and
lunch served between
12:00 p.m. and 1:00 p.m.
Day
3
8:00
a.m.
Continental Breakfast
8:30
a.m.
Responding to an OFCCP
Compliance Evaluation Scheduling Letter
•
Determining the Proper
Scope and Timetable for the Review
•
Analyzing and Determining
How Desk Audit Transactions Data Will Be Provided
•
Analyzing and Determining
How Desk Audit Compensation Data Will Be Provided
•
Other Pre-Submission
Analyses
OFCCP's Desk Audit Analyses
and Focus on Systemic Discrimination
•
How and When OFCCP Analyzes
Workforce Demographic Data
•
Systemic Discrimination
- What It Means in General and How OFCCP Analyzes for
It
•
Issues That
Commonly Arise During Statistical Analyses of Employment
Transactions Data (Hires, Promotions, and Terminations)
•
What OFCCP Looks for When
Analyzing the Impact of Employment Selection Tests
•
Issues That
Commonly Arise During Statistical Analyses of Compensation
Data, Including Strategies for Responding to "Paragraph
11"
Managing Follow Up Requests
for Data
•
Deciding What and How Additional
Information Should Be Provided to OFCCP
•
Managing the Review Prior
to an Onsite Visit
Completing
the Evaluation
•
Managing the
On-Site Aspect of Compliance Evaluations, Including OFCCP's
New "Beck" Compliance Inspections
•
Managing Post-On-Site,
Pre-Closure Activities
•
How Compliance Evaluations
Can Be Closed
•
Responding to a Notice
of Violation
•
Responding to a Pre-Determination
Notice
•
Resolving Compliance Deficiencies
Through Conciliation Agreements
•
When Conciliation Fails
- OFCCP's Enforcement Authority and Procedures
3:00
p.m.
Adjourn
*There will be a 15-minute
break in the morning.
The preceding is a proposed
agenda. EEAC reserves the right to update and revise the
agenda based on changing laws, regulations, and issues.
