Affirmative Action Plan

NADUR · November 2005

Our company currently has about 42 employees with two more scheduled to start in the next month or so. We are getting really close to that 50-employee threshold. We are a bank and are subject to affirmative action when we hit 50 employees even though other employers may not be subject to it until they hit a higher number of employees. I need to know anything anyone can tell me about writing an affirmative action plan. If anyone has an example they'd be willing to share, that would be even better. I don't know where to begin! Thank you!

dchr9203 · November 2005

NADUR,

The DOL has a "sample" AAP for small businesses that can be tailored for your needs. Here's the link:
[url]http://www.dol.gov/esa/regs/compliance/ofccp/pdf/sampleaap.pdf[/url]

Also, here's another "resource" for information.
[url]http://www.hr-guide.com/data/074.htm[/url]

NADUR · November 2005

I can't thank you enough for the resources!

pork1 · November 2005

And that is what this forum is all about, HRs helping HRs.

PORK

HRCalico · November 2005

First, take a deep breath - it's not quite as scary as it seems, I promise! You can pay to have a consultant do it, but I found it wasn't that difficult to do myself. You may try doing a search on this topic, there has been some discussion before that may help you. (See below for a specific recent post.)

Try contacting your "local" OFCCP office and ask if they provide training. I spent four hours at the Omaha office and left with a completely highlighted book and step-by-step instructions. I then proceeded to put it on the back burner for three months, so by the time I picked it back up, I had forgotten most everything. They patiently answered my questions and even let me e-mail my "completed" plan in for them to review and tell me what I was missing. :>) I hope your experience is as good as mine was.

Cleveland District Office US Dept. of Labor ESA - OFCCP
Howard M. Metzenbaum Federal Building Courthouse
201 Superior Avenue, Room 514 Cleveland, Ohio 44114
Phone: (216) 522-7360 Fax: (216) 522-8210

Columbus District Office US Dept. of Labor ESA - OFCCP
200 North High Street Room 409 Columbus, OH 43215
Phone: (614) 469-5831 Fax: (614) 469-6606

Also, Ed from Georgia posted this over in the AAP thread in the Wage and Hour forum:
For banks, there's a very professional law firm in Atlanta that specializes in the creation of AA plans for the industry. The name is: Employment Law Compliance, Inc. Phone: (866) 801-6302.

NADUR · November 2005

Thank you so much for the information. Your suggestion sounds like a good one. And thanks for saying it's not as bad as it seems!

E Wart · November 2005

First, I wouldn't have one until it is absolutely necessary. Secondly, writing the plan is easly... its the monitoring, sending out letters, doing calculations etc that takes the time. If you don't know how to do one, it is worth paying someone to do it for you or going to the OFCCP. (They are really nice and knowledgable people, believe it or not.)
E Wart

mushroomHR · November 2005

Once you get the narrative part done you can pretty much use the same one each year. The tracking and calculations are very time consuming especially if you have a lot of personnel activity: new hires, terminations, promotions, transfers. I use an outside source to calculate the Availability Factors for us and do the rest of it myself. It usually takes me a month to put everything together and I keep track of all necessary information as I go along throughout the year. We are a 200-person manufacturing facility. Good luck.

NADUR · November 2005

I'm sure this will be showing my ignorance, but I have to ask. What does OFCCP stand for?

HRCalico · November 2005

Office of Federal Contract Compliance Programs

(I didn't know either, when I started. DOL's website has an A-Z browse function and that's where I found it. They oversee the AAPs)

KathyHR · November 2005

When I was at a bank a few years back & we hit the threshold I had a company write the initial plan & thereafter do the yearly calculations for me. If you're in the Columbus or Cincinnati area you can check with Employers Resource Association, [url]www.hrxperts.org[/url]. They were a big help.

NADUR · November 2005

Thanks for the information. We are in the Columbus area, so I'll definitely check into it.

Cheryl S SPHR · November 2005

We are a bank as well and use the Atlanta firm mentioned above in an earlier post. IMHO, it is very worthwhile -- I would not want to write the plan myself -- the narrative isn't too bad, but it's all that statistical analyses that would throw me.

Good luck!

gismo · November 2005

We are a Bank as well. Do you have an external auditor that you use, that is who got us up and running with ours and I just use the same form just update #'s each year.

NADUR · November 2005

We do have an external auditor. I hadn't thought of asking them, but I will certainly do that. Thanks.

Dutch2 · November 2005

I agree that is a great place to start. You might consider contacting others in your area or ask the audit firm for others that are in the same business that might share their AAP with you.
We too are a bank and 2 or 3 years back we were fortunate enough to be "randomly selected" by the DOL for a review of our APP.
We had thought we were on track, but it took us over a year to finally get this random review behind us. We even went so far as to attend their training seminars at their office trying to figure out just exactly what they wanted. We would have reports returned because they were simply in the wrong format. We ended up hiring a law firm, yes they were on roller-skates, to wrok with us and finally put this behind us.
Good luck....

Affirmative Action Plan

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