How to Evaluate Your Affirmative Action Program's Audit Readiness
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The webinar focuses on evaluating affirmative action programs for audit readiness, featuring speakers Julia Méndez and Rosemary Cox from PeopleFluent. It covers preparation strategies, documentation requirements, and best practices to ensure compliance with audits, as well as answers frequently asked questions. Participants are encouraged to engage via Q&A and group chat, and resources such as presentation slides will be made available after the event.
How to Evaluate Your Affirmative Action Program's Audit Readiness
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- 2. #TMwebinar Speakers: Julia Méndez, SHRM-CP, CDP, PHR, CAAP, CELS Principal Business Consultant PeopleFluent Rosemary Cox, SPHR Principal Business Consultant PeopleFluent How to Evaluate Your Affirmative Action Program’s Audit Readiness
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- 8. #TMwebinar Julia Méndez, SHRM-CP, CDP, PHR, CAAP, CELS Principal Business Consultant PeopleFluent How to Evaluate Your Affirmative Action Program’s Audit Readiness Rosemary Cox, SPHR Principal Business Consultant PeopleFluent
- 9. © PeopleFluent 2015 How to Evaluate Your Affirmative Action Program for Audit Readiness Julia Mendez, PHR, SHRM-CP, CAAP, CDP, CELS Principal Business Consultant Rosemary Cox, SPHR, SHRM-SCP Principal Business Consultant
- 10. 10© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • Audit selection • Preparing for an audit • Scheduling Letter • Best practices Agenda
- 11. 11© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness Have any of your locations been selected for an audit in the last 24 months? Yes No I don’t know Polling Question #1
- 12. 12© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness OFCCP AUDIT SELECTION
- 13. 13© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • Federal Contractor Selection System • Contracts First Initiative • Pre-Award audits • Complaint activity • Conciliation Agreement How are Establishments Selected?
- 14. 14© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • Receive a Corporate Scheduling Announcement Letter (CSAL) • OFCCP contacts contractor by phone • Receive audit notice by certified mail How is a Contractor Contacted for a Review? How often can an establishment be reviewed?
- 15. 15© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness What if the audit notice has been floating around or we need more time to prepare for the submission?
- 16. 16© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness How do you prepare your clients for an audit?
- 17. 17© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • Schedule meeting with appropriate personnel • Review AAP and reconcile data • Are correct people in the AAP? • Are includes/excludes appropriate? • Are manager/supervisors notated? • Is compensation data complete? • Do you have adverse impact in any area? • Can you produce documentation? • Are disposition codes correct? • Have you performed a step analysis? Preparing for an Audit
- 18. 18© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • Are transactions correct (hires, promotions, transfers, terminations)? • Do the prior year totals – plus and minus the transactions – accurately reflect the current year totals? • Review and make appropriate edits to narratives • Ensure good-faith efforts are documented • Prepare package for OFCCP submission Preparing for an Audit
- 19. 19© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness Does someone within your company review the integrity of data before analysis/AAPs are run? Yes. We audit the data prior to running plans No. Our vendor “scrubs” the data we send them No. We run the reports with the data “as is” I don’t know Polling Question #2
- 20. 20© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness So what exactly is in the Scheduling Letter?
- 21. 21© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 1. Organizational Profile (aka Work Force Analysis). 2. Formation of job groups (Job Group Analysis). 3. For each job group, statement of % of minority and female incumbents (JGA). 4. For each job group, determination of minority and female availability (Availability Analysis). 5. For each job group, comparison of incumbency to availability (Incumbency vs. Availability). 6. Placement Goals for each group where incumbency is less than availability. Itemized Listing
- 22. 22© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 7. Results of evaluation of effectiveness of outreach and recruitment efforts to identify and recruit qualified IWD. 8. Documentation of all actions taken to comply with audit and reporting system requirements. 9. Documentation of computations or comparisons described in 41 CFR 60-741.44(k) for preceding AAP year and if 6 months or more into current AAP year, information for at least the first 6 months of the current AAP year. Itemized Listing Section 503
- 23. 23© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 10. Utilization analysis evaluating representation of IWDs in each job group (or entire workforce, if appropriate). If 6 months or more in current AAP year on date receive the scheduling letter, submit information that reflects current year progress. Itemized Listing Section 503
- 24. 24© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 11. Results of evaluation of effectiveness of outreach and recruitment efforts. 12. Documentation of all actions taken to comply with audit and reporting system requirements. 13. Documentation of computations or comparisons described in 41 CFR 60-300.44(k) for immediately preceding AAP year and, if 6 months or more into current AAP year, information for at least the first 6 months of current AAP year. Itemized Listing Section 4212 (VEVRAA)
- 25. 25© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 14. Documentation of hiring benchmark, methodology used to establish it if using 5 factors. If 6 months or more into current AAP year, submit information that reflects current year results. Itemized Listing Section 4212 (VEVRAA)
- 26. 26© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 15. Copies of EEO-1 for last three years. 16. Copy of CBA. Include other documents such as policy statements, employee notices or handbooks, etc. that implement, explain, or elaborate on provisions of CBA. 17. Information on AA goals for immediately preceding AAP year and progress on goals for the current AAP year. If 6 months or more into current AAP year, submit info that reflects progress on goals established in current AAP year and describe implementation of action-oriented programs designed to achieve these goals. Itemized Listing Supporting Data
- 27. 27© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 18. Data on employment activity for immediately preceding AAP year and, if 6 months or more into current AAP year, information for at least the first six months of the current AAP year. Information can be presented by job group or job title. a. Applicants and hires: Total number of applicants and total number of hires, minority break out information, female/male information. Unknown race and/or sex should be included in data submitted. b. Promotion: Total number of promotions by gender and race/ethnicity. Include definition of “promotion” as used by your company and basis on which they are compiled. Itemized Listing
- 28. 28© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 18. (continued) c. Terminations: For each job group or job title, provide total number of employee terminations by gender and race/ethnicity. When presenting terminations by job title, include the department and job group from which the person(s) terminated. 19. Employee level compensation data for all employees (including full-time, part-time, contract, per diem or day labor, temporary) as of date of the workforce analysis in AAP. Provide gender and race/ethnicity information and hire date for each employee as well as job title. Itemized Listing
- 29. 29© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 19. (continued) a. For all employees, compensation includes base salary and or wage rate, and hours worked in a typical workweek. Other compensation or adjustments to salary such as bonuses, incentives, commissions, merit increases, locality pay or overtime should be identified separately for each employee. b. Contractor may provide any additional data on factors used to determine employee compensation (education, past experience, duty location, performance ratings, department or function, salary level/band/range/grade) c. Documentation and policies related to compensation practices should be included in the submission Itemized Listing
- 30. 30© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness 20. Copies of reasonable accommodation policies and documentation of any accommodation requests received and their resolution, if any. 21. Most recent assessment of personnel processes including the date assessment was performed, any actions taken or changes made as a result of the assessment, and the date of next scheduled assessment. 22. Most recent assessment of physical and mental qualifications including date of assessment, actions taken or changes made as a result of assessment, and date of next scheduled assessment. Itemized Listing
- 31. 31© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness Notes under Item #22 state “If any of the requested information is computerized, you must submit it in an electronic format that is complete, readable, and useable.” Itemized Listing
- 32. 32© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness What types of requests are you seeing today that are taking contractors by surprise?
- 33. 33© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness So after all of this, what may be the outcome of the audit?
- 34. 34© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • Compliance Evaluation Closure Letter • No violations • Minor violations • Conciliation Agreement • Major violations Outcome of Compliance Review
- 35. 35© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • FY 2014 = 3,802 compliance evaluations and 501 conciliation agreements • September 2014 – April 8, 2015 = 1,333 compliance evaluations with 220 conciliation agreements (16.50%) OFCCP Activity
- 36. 36© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • May 2015: Manufacturer in Alabama will pay $115,000 in back wages, interest to 159 applicants; systemic hiring discrimination against 83 women and 19 African Americans • April 2015: Media and technology company in Seattle, Washington: $190,000 settlement for back wages and interest to 96 former and current female employees and 100 minority job applicants Selection Discrimination
- 37. 37© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness • February 2015: Massachusetts medical center will pay $190K in back wages, interest and salary adjustments • January 2015: Research university and hospital in Maryland; $360K in back wages and damages for two African American women Pay Discrimination
- 38. 38© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness Polling Question #3 If you were selected for an audit today, how prepared would your organization be? Well prepared Somewhat prepared Not prepared Don’t know
- 39. 39© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness What are some best practices that we can put into place now to prepare for an audit?
- 40. 40© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness Best Practices • Review job groups, labor areas, and other plan data prior to writing an AAP • Reconcile data and ensure accuracy for AAP prior to audit • Review compensation annually (make changes if needed) • Document and review effectiveness of GFE • Hold managers, recruiters, HR staff accountable for progress and GFE
- 41. 41© 2015 PeopleFluent How to Evaluate Your AAP’s Audit Readiness Best Practices • Review processes and procedures to ensure being carried out • Review website and facilities for accessibility • Take employees seriously • Take tours of facilities • Investigate adverse impact • Review record retention requirements • Train HR, recruiters, managers, employees
- 42. TM © 2014 PeopleFluent | Confidential Talent Insights. Business Outcomes.TM Thank You Find PeopleFluent on… Twitter: twitter.com/peoplefluent LinkedIn: linkedin.com/company/peoplefluent Facebook: facebook.com/peoplefluent Blog: peoplefluent.com/resources/peoplefluent-blog Julia Méndez, Principal Business Consultant julia.mendez@PeopleFluent.com Rosemary Cox, Principal Business Consultant rosemary.cox@PeopleFluent.com DISCLAIMER: The information provided in this presentation is for educational and informational purposes only. It does not constitute legal advice or legal opinions. PeopleFluent makes no claims, promises or guarantees about the accuracy, completeness or adequacy of the information contained herein. Nothing that is provided in this presentation should be used as a substitute for the advice of legal counsel. Questions?
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