Preparing Your Data for AAP Development and Possible Audit€¦ · of BQ: •Non-Comparative...
Transcript of Preparing Your Data for AAP Development and Possible Audit€¦ · of BQ: •Non-Comparative...
Preparing Your Data for AAP Development and Possible
Audit Part I: Data Preparation
A presentation of the
BCG Institute for Workforce Development (BCGi)
Biddle Consulting Group Inc. Affirmative Action Plan (AAP)
Consulting and Fulfillment
• Thousands of AAPs developed each year • Audit and compliance assistance • myAAP™ Enterprise software
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•“High stakes” test development •Validation studies in response/prevention to litigation
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Compensation Analysis • Proactive and litigation/enforcement pay equity studies • COMPare™ compensation analysis software
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Biddle Consulting Group Institute for Workforce Development BCGi Memberships (free): ~8000+ members / 18,000+ HRCI credits to-date
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EEO Insight Journal (e-copy and hardcopy)
Access to the BCGi library of webinars, training materials, and much more …
www.bcginstitute.org
A few housekeeping items:
Contact Information Biddle Consulting Group, Inc. (BCG)
193 Blue Ravine, Suite 270 Folsom, CA 95630
916.294.4250 www.biddle.com
www.bcginstitute.org
Marife Ramos, PHR, SHRM-CP [email protected]
ext. 129
Tony Mentessi [email protected]
ext. 132
Agenda: Part I
Who’s Included in the AAP?
What Data do I Need?
What goes into Determining my Availability?
In Conclusion: Summary, Questions and Answers
Who’s Included in the AAP?
Which employees are included?
• Each employee in the contractor’s workforce
Who are employees?
• The term ‘employee’ is broad enough to include part-time,
temporary, and full-time employees
• Are they on your payroll as of snapshot date (one day in time)?
• Field employees roll into manager’s location – move up the chain
Who’s Included in the AAP?
Identifying the Corporate Initiative Employees:
Organizations are required to identify employees who work in one AAP
location while being on the payroll at another AAP locations and/or
report to a manager at another AAP location.
• Employees who physically work at a given location will have to appear in
the Workforce Analysis of that physical location (with annotation); but
nowhere else in that AAP.
• The employees who report to another location are included in all AAP
reports of that other location.
Who’s Included in the AAP?
How to Define Corporate Initiative Employees:
Recommendations:
Include Employees in the AAP of their supervisor
or
Those who are in certain “levels” (e.g., Executives, pay grade, etc.)
Who’s Included in the AAP?
What Data do I Need?
An Affirmative Action Plan is a set of goal oriented management policies and procedures designed to identify and eliminate barriers to employment opportunities. By evaluating diversity in an organization’s workforce and ensuring personnel processes/procedures are fair to all, we get a better understanding if any impediments exist. This is accomplished by taking a look at the organization at a single point in time and analyzing everything that has occurred over the past 12 months
What Data do I Need?
What Data do I Need?
Data Requirements to Complete an AAP:
Employee Data – As of a specific date (snapshot date) in time Example – Using 12/31/2016, we want to capture all employees on the
payroll as of this date.
Transaction Data – Applicants, Hires, Promotions, and
Terminations that occurred during the 12 months prior to the selected snapshot date
Example – Using 12/31/2016 as the snapshot date, we would pull all
transactions that occurred between 1/1/2016 and 12/31/2016.
Employee Identifier – A unique identifier for each employee (e.g., Last four digits of SSN) Hire Date – The date the employee was hired Gender – Sex of employee (M/F) Race – Employee’s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran – Employee’s veteran status (Y/N) Disability – Employee’s disability status (Y/N) Job Code – The code assigned to each unique job title Job Title – The title of the employee’s job Job EEO Category – The EEO Category for the job title Salary – The Employee’s base salary amount Organizational Unit 1 – The department the individual works in Physical/Work Site – Where the employee is physically located Reporting Site – AAP reporting location
Includes all active employees on your payroll as of the snapshot date
What Data do I Need? Employees File
Typical Issues Encountered
• Missing Gender/Race information o Best solutions:
Re-survey the workforce to obtain this information Have the direct supervisor visually identify (if they are comfortable doing so)
• Missing Salary information o Use pay grade (if applicable) o Rank order by department
• Differing Job information o Ensure that job information matches across the files
What they applied for is what they were hired on as, what they were promoted to is the current title listed in the employee file, etc.
What Data do I Need? Employees File
Additional Required Data Fields (if applicable)*: Pay Grade – Salary Band Full/Part Time Status – Full-Time or Part-Time employee Date in Job – Date the employee filled the current job Commission – Total additional compensation (in the form of commission) that the employee received Incentives – Providing employees with incentives to receive pay increase Bonuses – Total additional compensation that the employee received: holiday bonuses, quarterly bonuses,
annual bonuses, etc. Merit Increases – Performance appraisals Overtime Pay – Amount of overtime pay earned during the previous 12-month period Exempt/Non-Exempt Status – Employee’s FLSA status Hours Worked – Number of hours work in a typical workweek for part-time employees
*These additional fields are required during an OFCCP Audit
What Data do I Need? Employees File
What Data do I Need? Applicants File
Gender – Sex of Applicant (M/F/U) Race – Applicant’s ethnicity (W, B, H, A, I, 2+, NHOPI, U) Protected Veteran – Applicant’s veteran status (Y/N/Did Not Provide) Disability – Applicant’s disability status (Y/N/Did Not Provide) Job Code – The unique code of the job title to which the applicant applied Job Title – The job title to which the applicant applied Job EEO Category – The EEO Category for the job title Reporting Site – AAP reporting location Applicant Type – Identifying if it was an external or internal candidate Application Date – The date the applicant applied
Include all applicants associated to the hires made within your transaction period
3. Individual Possesses
Basic Qualifications
3 Conditions
of BQ: •Non-
Comparative •Objective •Relevant
2. Contractor Considers
Individual for a Particular
Position
Required
Optional
Solicit Race/Ethnicity, Gender, Protected Veteran, & IWD
1. Individual Submits
Expression of Interest
(Electronic)
4. Individual Does NOT
Self-Eliminate
Before Offer is Made
5. Individual is an
Applicant
Retain Records
Individuals who meet all 4 “prongs” are applicants and will be included in the Personnel Transactions and Adverse Impact Analyses
What Data do I Need? Internet Definition of an Applicant
Employee Identifier – Hire’s unique identifier Gender – Sex of employee (M/F) Race – Employee’s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran – Employee’s veteran status (Y/N) Disability – Employee’s disability status (Y/N) Job Code – The code assigned to each unique job title Job Title – The job title the individual was hired into Job EEO Category – The EEO Category for the job title Hire Date – The date the employee was hired Reporting Site – AAP reporting location
Includes all new hires or rehires made within the transaction period
What Data do I Need? Hires File
What Data do I Need? Hires File
Typical Issues Encountered
• How are Seasonal Employees handled?
• What if someone was hired outside the transaction period, but actually started working within the transaction period? o Is it when the decision to hire was made or when the start date occurred?
• Missing Gender/Race information
Employee Identifier – A unique identifier for promoted employee Gender – Sex of employee (M/F) Race – Employee’s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran – Employee’s veteran status (Y/N) Disability – Employee’s disability status (Y/N) Job Code From – The code assigned to the employee’s previous job, the one promoted from Job Title From – The title of the job from which the employee was promoted from Job EEO Category From – The EEO Category for the job title that the employee was promoted from
Includes all promotions made within the transaction period. Promotions depend on what your organizations definition of a promotion is
What Data do I Need? Promotions File
Job Code To – The code assigned to the employee’s previous job, the one promoted from Job Title To – The title of the job from which the employee was promoted from Job EEO Category To – The EEO Category for the job title that the employee was promoted from Promotion Type – Competitive or Non-competitive (if applicable) Promotion Date – The date the employee was promoted Reporting Site From – Previous AAP reporting location Reporting Site To – Current AAP reporting location
What Data do I Need? Promotions File
What Data do I Need? Promotions File
Typical Issues Encountered
• What if someone was hired internally? o Is it a promotion or is it a hire? o Should transferred be analyzed?
• Mismatching job information between the Employee and Promotion files
• What if they were promoted multiple times during the transaction period?
Employee Identifier – A unique identifier for each terminated employee Gender – Sex of terminated employee (M/F) Race – Ethnicity of terminated employee(W, B, H, A, I, 2+, NHOPI) Protected Veteran – Terminated employee’s veteran status Disability – Terminated employee’s disability status (Y/N) Termination Code – The type of termination (e.g., voluntary, involuntary) Job Code – The code assigned to each unique job title Job Title – The job title of the employee at the time of termination Job EEO Category – The EEO Category for the job title Termination Date – Date the employee was terminated Reporting Site – AAP reporting location
Includes all terminations made within the transaction period
What Data do I Need? Terminations File
Includes all terminations made within the transaction period
What Data do I Need? Terminations File
Typical Issues Encountered
• Should seasonal employees be included?
• Determining voluntary vs. involuntary terminations
• Are they still included in the employee file?
Applicants File
Hires File
Employees File
Jane applied for an open position and was hired within the transaction period.
What Data do I Need?
Jane was terminated within the transaction period.
Applicants File
Hires File
Terminations File
Employees File
What Data do I Need?
Applicants File
Employees File: reflect current jobs information
Jane was promoted within the transaction period.
What Data do I Need?
Hires File
Promotions File
What goes into Determining my Availability?
• A central premise underlying affirmative action is that, assuming all else being equal (and absent of discrimination), over time a contractor’s workforce will reflect the gender, racial and ethnic profile of those with the “requisite skills” in the labor areas from which the contractor recruits and selects.
• If a contractor’s workforce doesn’t reflect this labor profile, that’s when action-oriented programs and outreach & recruitment resources are used to help reach the observed profile.
• So what goes into determining what we “should” look like?
What goes into Determining my Availability?
What we “should” look like is referred to as the “final availability”
• It’s an estimate of the number of qualified minorities or women available for employment in a given job group
• It’s a combination of internal and external availabilities (i.e., factors) to identify what those qualified to work in the job group are “supposed” to look like
• Once a final availability is calculated, we are able to compare the current composition of the job group to it an determine if underutilization exists
What goes into Determining my Availability?
External Factor (i.e., typically census data)
• Step 1: Define the labor areas (local, state, national)
• Step 2: Assign census occupation codes to all jobs (487 available to choose from)
• Step 3: Mathematically weight census codes based upon representation within each job group
• Step 4 (Optional): Identify other relevant data besides the census (e.g., graduate data)
Internal Factor (i.e., “feeder” data)
• Step 1: Identify feeder jobs/job groups (those employees who are “promotable and/or transferable”)
• Step 2: Mathematically weight feeders based on relevance (e.g., flow/movement of internal employees)
IMPORTANT NOTE: Results are only as good as the amount of effort put into this process! But don’t get caught in the weeds … this is equal parts art and science!
What goes into Determining my Availability?
What goes into Determining my Availability?
Example: Happy Software location in San Mateo
Happy Software Corp. HQ (500 Employees)
Software Developers (2006-2010) Male Female White Black Hispanic Asian NHOPI AIAN 2+
SF MSA 80.0% 20.0% 42.3% 1.3% 3.1% 52.0% 0.1% 0.3% 0.9%
Male Female White Black Hispanic Asian NHOPI AIAN 2+
SJ MSA 78.1% 21.9% 30.1% 0.8% 2.3% 65.5% 0.0% 0.2% 1.2%
San Mateo: 30% Santa Clara: 30% Alameda: 12% Santa Cruz: 10% San Francisco: 10% Marin: 3% Contra Costa: 3% Stanislaus: 2%
“Trim” spurious and/or misleading labor areas, including those that have negligible contributions
What remains is the local labor area (with corresponding weights)
What goes into Determining my Availability?
External Factor – Step 1: Define the Labor Area(s)
Zip Code or Manual Identification
• Census occupation codes (aka “census codes”) are links between your jobs and the external census data
• Each distinct job is assigned to one (or more) of the 487 codes
2010 Census Code Toolkit
• The census data for each code is weighted based upon it’s representation within each job group.
What goes into Determining my Availability?
External Factor – Step 2: Assign Census Occupation Codes
What goes into Determining my Availability?
External Factor – Step 2: Assign Census Occupation Codes
62.3% of the employees in this job group are in jobs assigned to code 7830
What goes into Determining my Availability?
External Factor – Step 3: Weight Census Occupation Codes
• Miscellaneous (potentially) available data sets
o Graduate Data
o Internal/external training course attendees
o Mentorship programs
o ?
What goes into Determining my Availability?
External Factor – Step 4: Identify relevant data other than that from Census
• Internal Factor:
o Positions are not always filled via external sources… it’s also necessary to identify internal sources of availability information
o Step 1: Identify “feeders” for all job groups
o Step 2: Weight feeders based on historical promotions data (i.e., data-driven… for starters… with a heavy dose of personal review because there will be crazy situations.
Target Job Group Weight Feeder Job Group
1A – Management 75.0 1B – Middle Management (Directors)
25.0 1C – Managers/Supervisors
What goes into Determining my Availability?
Internal Factor – Step 1: Identify relevant feeders
What goes into Determining my Availability?
Internal Factor – Step 1: Identify relevant feeders
Note: Job groups should never be a feeder for themselves.
50.0% of the internal movements into job group 7-03 come from job group 7-05
What goes into Determining my Availability?
Internal Factor – Step 2: Weight feeders
• Factor Weights:
o The weight given to the internal and external availability data (i.e., factor) for each job group
o Identifies the relative “importance” of each set of data
• Assigning factor weights requires the used to ask the following question:
o “Out of 100 hypothetical movements into this job group, what number do I expect to come from a local recruitment area, national (or other reasonable) recruitment area, or an internal pool?”
What goes into Determining my Availability?
Final Availability: Assigning Factor Weights
Raw (%) x Factor Weight = Weighted (%)
What goes into Determining my Availability?
What We Should Look Like: Final Availability
Raw (%) x Factor Weight = Weighted (%) Final Availability (%) = Goal
In Conclusion: Summary, Questions and Answers
Summary
• The term ‘employee’ is broad. If part-time, full-time, and/or temporary
employees appear on your payroll as of the snapshot date, they should be
covered under an AAP.
o Be sure to identify any Corporate Initiative employees.
• Be careful of data collection pitfalls and do not get hung up on information
that you do not need for development.
o Reconciling data is essential for making audit ready Affirmative Action Plans.
o Only include applicants in which a selection was made during the transaction
period.
Summary
• The final product will only be as good as the data that you put in.
o Ensure you have all the required data and you’re determining your final
availability properly, as this will have a huge impact on the results.
o Make sure that you assign the appropriate Census Occupation Code for each
job title and review your Factor Weights & Feeders annually.
• Most importantly, if you need help, be sure to reach out and seek the
guidance that you require from an HR professional, Consultant, or Legal
Counsel.
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