For those of you with calendar year AAPs, this month begins the mad dash to just get your AAPs completed, but I urge you to pause and take stock of the non-statistical elements of your AAP. The OFCCP has sent out the Corporate Scheduling Announcement Letters (CSALs) and this year you will see audits handled alittle differently. Active case management has been discontinued which means focusing solely on systemic discrimination is a thing of the past and the agency will be taking a deeper look at the AAPs submitted for desk audit.
Some of the things the OFCCP will have a renewed focus on are the Additional Required Elements required in Section 60-2.17:
Designation of Responsibility: Take this seriously, those who are named as having responsibility for oversight and implementation of your affirmative action program should have the authority, resources and support to follow through on those commitments.
Identification of Problem Areas: OFCCP wants to see that you are analyzing all areas of employment that may have an impact on the success of your affirmative action program. So don’t just complete the statistical portions of your AAP, but analyze them thoroughly for issues.
Action Oriented Programs: Evaluate the good faith efforts and outreach that you did last year, measure whether their success and make adjustments where needed.
Internal Audit and Reporting System: OFCCP wants you to measure the effectiveness more than once a year. Make sure that records are being maintained, policies are being carried out properly and consistently and management at all level is being advised of the progress and results throughout the plan year.