Employers that implement and fully embrace an Affirmative Action Program (AAP) understand that it can be an effective management tool instead of just a paperwork distraction. These employers move beyond the basics of the regulatory requirements and integrate the AAP into their workforce management strategy. The Office of Federal Contract Compliance Programs (OFCCP) has strived to motivate employers by stating, “there is a positive correlation between the presence of affirmative action and the absence of discrimination” (41 CFR §60-2.10(a)(1)). In fact, the program should be considered a business plan for each manager. The business plan needs to include the initial assessment of each component of an organization, identification of problem areas, a set of goals, and a periodic progress to goals report. This is true of the AAP for Women and Minorities but perhaps even more critical for Individuals with Disabilities (IWD) and Veterans. The agency is expecting organizations to measure their progress (or lack of) in meeting their goals and modifying their strategy when insufficient progress is made.
One of the keys to incorporating the AAP into your workforce management strategy is getting buy-in from your management team. The program must be developed so that it becomes a useful and effective tool for your managers. The executive management team must clearly demonstrate their commitment to the program and hold each member of the management team accountable to meeting the goals defined in the AAP. As part of this commitment, organizations need to include AAP goals in their manager’s annual performance review. Each manager’s annual performance must be evaluated based on achieving their AAP Goals and annual merit increases should be impacted based on achievement of the goals.
How to Define Managers’ AAP Goals
Leading employers understand that managers require AAP goals that are reasonable, relevant, and attainable. The goals must be based on a process that produces targets in alignment with the:
- Manager’s areas of responsibility
- Race / gender / ethnicity demographics of the workforce they manage
- Skill set of their workforce
The targets must be relevant and attainable otherwise you risk losing your management team’s buy-in and commitment to the program. This is especially true if their compensation is affected by their ability to meet their AAP goals.
Developing manager-level targets through starting at the corporate-level goals and using a simple average or weighting methodology to determine an individual manager’s target is insufficient and not supportable. Many organizations make this attempt, but it typically does not have manager buy-in because the goals cannot be statistically supported and results in an ineffective AAP. Therefore, a manager’s organization must be analyzed like a ‘mini-AAP’ where the workforce is analyzed through a fully detailed incumbency versus availability analysis using the relevant mix of occupational categories, labor area demographics and relevant weighting of internal and external factors to arrive at attainable placement goals.
Go Beyond OFCCP goals, Measure the ROI of Affirmative Actions Programs
Employers commonly use pre-defined goals for IWD and Veterans AAPs as defined by the OFCCP. However, progress to goals for IWD and Veteran AAPs should also follow the same approach as we described earlier. Hold each individual manager accountable to meeting the goals and provide frequent and regular feedback on progress to goals. The OFCCP is also expecting organizations to develop an ROI (Results on Investment) when it comes to goals for IWD and Veterans.
Producing a regular reporting schedule will provide managers with feedback on their efforts so they can adjust their business practices accordingly throughout the year. In addition, progress measurement must be provided on a frequent and regular basis to executive management regarding each manager’s efforts and progress in attaining their goals.
The ability to manage compliance and diversity documentation fluidly throughout your organization is crucial to the success of your AAP. PeopleFluent’s Complete Resource Center (CRC) streamlines the process of administering and monitoring your AAP by centralizing all key information, action items, and results. CRC is an online asset-management system for administering your Affirmative Action and Diversity efforts and provides a centralized, secure platform to house a wide array of compliance information. PeopleFluent has recently enhanced CRC’s user interface, updated the audit alerts dashboard, and improved the Good Faith Efforts library along with many other enhancements.
Learn more about PeopleFluent’s variety of solutions available to support your Affirmative Action Program.