The Narrative Review: What
Goes Into the Written Portion of
an AAP
June 10, 2015
John Piatt
Mackenzie Martin
Overview of Biddle Consulting Group, Inc.
Affirmative Action Plan
(AAP) Consulting and
Fulfillment
HR Assessments
Custom Test Development &
Validation
• Thousands of AAPs developed each year
• Audit and compliance assistance
• AutoAAP™ Enterprise software
• AutoGOJA™ online job analysis system
• TVAP™ test validation & analysis program
• CritiCall™ pre-employment testing for 911 operators
• OPAC™ pre-employment testing for admin professionals
• Video Situational Assessments (General and Nursing)
•“High stakes” test development
•Validation studies in response/prevention to litigation
EEO Litigation Consulting
/Expert Witness Services
• Over 200+ cases in EEO/AA (both plaintiff and defense)
• Focus on disparate impact/validation cases
Compensation Analysis
• Proactive and litigation/enforcement pay equity studies
• COMPare™ compensation analysis software
Publications/Books
BCG Institute for Workforce
Development
Speaking and Training
• EEO Insight™: Leading EEO Compliance Journal
• Adverse Impact (3rd ed.) / Compensation (1st ed.)
• 4,000+ members
• Free webinars, EEO resources/tools
• Regular speakers on the national speaking circuit
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Biddle Consulting Group Institute for
Workforce Development (BCGi)
• BCGi Memberships (free): ~6000+ members / 15,000 HRCI
credits to-date
– Online community
– Monthly webinars on EEO compliance topics
– EEO Insight Journal (e-copy)
• BCGi Platinum Membership (paid)
– Includes validation/compensation analysis books
– EEO Tools including those needed to conduct AI analyses
– EEO Insight Journal (e-copy and hardcopy)
– Access to the BCGi library of webinars, training materials, and much more …
www.bcginstitute.org
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Contact Information
Biddle Consulting Group, Inc.
193 Blue Ravine, Suite 270
Folsom, CA 95630
916.294.4250
www.biddle.com | www.bcginstitute.org
John Piatt ([email protected])
Mackenzie Martin ([email protected])
Copyright (c) 2013 Biddle Consulting Group, Inc
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Agenda
Why Contractors have to Create Narrative
Review of Each Section in Narrative
Techniques of Managing Narrative
Techniques for Bolstering Action-Oriented
Programs
In Conclusion: Summary, Questions, and
Answers
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Why Contractors have to Create
Narrative
Narratives for Affirmative Action Programs
Three (3) types of written Affirmative Action Programs:
1) AAP for Minorities & Women (E.O. 11246)
2) AAP for Disabled (Sec. 503 of the Rehabilitation Act)
3) AAP for Protected Veterans (VEVRAA)
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Why Contractors have to Create
Narrative
1) Narrative for Women and Minorities
Executive Order (E.O.) 11246
Requires Federal contractors to create an AAP (including
narrative) if they meet one of the following criteria:
•
50 or more employees and $50,000 or more in contract revenue
during a 12 month period
•
Serves as a depository of Government funds in any amount
•
A financial institution who issues and pays U.S. saving bonds or
saving notes
Ref: 41 CFR 60-2.1 (b) (1) (i-iv)
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Why Contractors have to Create
Narrative
2) Narrative for Individuals with Disabilities
Section 503 of the Rehabilitation Act of 1974, as
amended
Any contract in excess of $10,000 for personal property and
non-personal services (including construction) shall contain a
provision requiring that the party contracting with the
government shall take affirmative action to employ and advance
in employment qualified individuals with disabilities.
Ref: 41 CFR 60-741
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Why Contractors have to Create
Narrative
3) Narrative for Veterans
Vietnam Era Veterans' Readjustment Assistance
Act of 1974, as amended
• Any contract of $100,000 entered into, or modified, on or
after December 1, 2003
Covered contractors “shall take affirmative action to employ and
advance in employment qualified protected veterans.”
•
Disabled veterans, recently separated veterans, active duty
wartime or campaign badge veterans, and Armed Forces
service medal veterans are protected veterans under
VEVRAA.
Ref: 41 CFR 60-300
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Why Contractors have to Create
Narrative
Thresholds
Contract
Amount
Disabled
Section 503 of
Rehabilitation
Act of 1973
Women &
Minorities
Executive Order
11246
Veterans
Vietnam Era
Veterans'
Readjustment
Assistance Act of
1974
$10,000
$50,000
$100,000
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Why Contractors have to Create
Narrative
Narrative Content for Women and Minorities
Explanatory chapters
•Chapters 1-6 (explains the technical reports) [Optional]
Designation of Responsibilities
•Who is responsible to implement the AAP
─
President CEO, HR Manager, AA Officer, Managers and Supervisors
Identification of Problem Areas
•Do impediments to EEO exist?
Action Oriented Programs
•The implementation portion of the AAP
Internal Audit and Reporting
•Measures the effectiveness of the AAP
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Why Contractors have to Create
Narrative
Narrative Content for Veterans and Individuals with
Disabilities
Required Components
Vets
IWDs
1. Equal Opportunity Policy Statement
√
√
2. Review of Personnel Processes
√
√
3. Review of Physical and Mental Qualifications
√
√
4. Reasonable Accommodations to Physical and Mental Limitations
√
√
5. Commitment to Anti-Harassment
√
√
6. External Dissemination of Policy, Outreach, and Positive Recruitment
√
√
7. Internal Dissemination
√
√
8. Audit and Reporting System
√
√
9. Identification of Responsibility for Implementation
√
√
10. Training
√
√
Hiring
Benchmark
Utilization
Goal
11. Data Collection and Analysis
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Why Contractors have to Create
Narrative
Overall “Big Picture”
Step 1: Availability Analysis
Identifies the gender and race
composition of the available
workforce
Step 4: Action-Oriented
Programs
Affirmative steps that will
be taken to help achieve
goals
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Step 2: Comparison of
Incumbency to Availability
Identifies differences between
current incumbency and
available workforce
Step 3: Placement Goals
Calculates the goal needed to
eliminate underutilization for
where differences exist
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Review of
Each
Section in
Narrative
Review of Each Section in Narrative
Chapter 1: Organizational Profile
Chapter 2: Job Group Analysis
Chapter 3: Placement of Incumbents in Job Groups
Chapter 4: Determining Availability
Chapter 5: Comparing Incumbency to Availability
Chapter 6: Placement Goals
• Explanation of the technical reports
• These chapters aren’t required
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Review of Each Section in Narrative
Chapter 7: Designation of Responsibility
• Required component
• Stating who is responsible for the implementation of
the AAP
• What are the commitments for upholding the AAP?
• Annually review/update the responsibilities listed for
each officer as necessary
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Review of Each Section in Narrative
Chapter 8: Identification of Problem Areas
• Required component
• Derived from placement goals for women and
minorities
• Identify which job groups/areas that posed a concern
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Review of Each Section in Narrative
Chapter 9: Action-Oriented Programs
• Required component
• OFCCP hotspot
• “Good faith efforts” to remedy problem areas from
chapter 8
• Prepare a list of programs that your company has
implemented, planning to implement, and/or
currently undertaking in order to achieve diversity in
the workforce
• Annually review/update as necessary
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Review of Each Section in Narrative
Chapter 10: Internal Audit and Reporting
• Required component
• Identify what your company is doing to uphold
chapter 9
• Periodically audit yourself internally
• Document actions/steps for success
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Review of Each Section in Narrative
Chapter A: Policy Statement
• Required component
• Company’s statement of commitment to uphold
Affirmative Action and Equal Employment
Opportunity for all
• Must show the U.S. top executive’s full support
• Recommended to have U.S. top executive's signature
• Annually reviewed/updated as necessary
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Review of Each Section in Narrative
Chapter B: Review of Personnel Processes
Chapter C: Physical and Mental Qualifications
Chapter D: Reasonable Accommodation to Physical
and Mental Limitations
Chapter E: Harassment
• Required components
• Annually reviewed/updated as necessary
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Review of Each Section in Narrative
Chapter F: External Dissemination of Policy,
Outreach, and Positive Recruitment
• Required component
• OFCCP hotspot
• “Good faith efforts” to positively recruit to veterans
and individuals with disabilities
• Prepare a list of programs that your company has
implemented, planning to implement, and/or
currently undertaking in order to achieve diversity in
the workforce
• Annually review/update as necessary
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Review of Each Section in Narrative
Chapter G: Internal Dissemination of Policy
Chapter H: Audit and Reporting System
• Required components
• Annually reviewed/updated as necessary
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Review of Each Section in Narrative
Chapter I: Responsibility for Implementation
• Required component
• Stating who is responsible for the implementation of
the AAP
• What are the commitments for upholding the AAP?
• Annually review/update the responsibilities listed for
each officer as necessary
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Review of Each Section in Narrative
Chapter J: Training
Chapter K: Data Collection Analysis
Chapter L: Compensation
• Required component
• Annually review/update as necessary
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Techniques of Managing Narrative
• Use a word document that cites the reports as
appendices/exhibits
• Narrative prior to reports
Pros and cons?
• Narrative separated and included with the reports
Pros and cons?
• Larger companies vs. smaller companies
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Techniques of Bolstering ActionOriented Programs
•
Think outside of the box and DOCUMENT!
•
Document and emphasize ALL good faith efforts
•
Utilize diverse recruitment agencies
•
Advertize in publications
•
Attend all local diversity career/job fairs
•
Get involved in your community
Hold events to raise money that provides services to ensure that
children/adults with disabilities have equal opportunities to live, learn,
work, and play
Hold career shadow days to middle/high school students
•
Publish in-house recruiting brochures where minority, female,
veteran, and/or disabled members of the workforce are included
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Techniques of Bolstering ActionOriented Programs
•
Utilize the following organizations that provide services to
women and minorities:
American Association of University Women
Asian Women’s Self Help Association
Dress for Success – Washington, DC
Alexandria JobLink
Job Corps Center
Regional Chambers of Commerce
Year Up
Transitional Housing BARN, Inc. (BARN)
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Techniques of Bolstering ActionOriented Programs
•
Utilize the following organizations that provide services to
veterans and individuals with disabilities:
Laurie Mitchell Employment Center
Service Source
Vocational Rehabilitation
Department of Rehabilitative Services
Military Veteran Centers
American Women Veterans
Disabled American Veterans
Employer Partnership of the Armed Forces
Army Career & Alumni Program
Veterans Affairs Department
Corporate Gray
Sheridan Walker – HirePotential
Acceptance programs
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Techniques of Bolstering ActionOriented Programs
•
Create mentoring programs
Create an environment for employees to navigate paths to connect,
learn, and grow
The mentee benefits from the program: enhancing the employee’s
understanding of the company, expanding their professional network,
opportunities for accelerated learning, and exposure to a variety of
career paths
•
Encourage employees to actively participate in companysponsored social and recreational activities to improve
attraction and retention of minority, female, veteran, disabled
employees
This encouragement comes fin may forms including awards and
opportunities
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Techniques of Bolstering ActionOriented Programs
•
Cultural awareness
Celebrate respective histories and heritage months with guest
speakers, cultural programs, and entertainment
•
Provide funding/grants to specialized organizations geared
towards women, minorities, veterans, and individuals with
disabilities (if budget allows for)
Have fundraisers
•
Initiate carpooling and van programs to drive employees (if
budget allows for)
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Techniques of Bolstering ActionOriented Programs
BIG PICTURE
Your company wants to ensure that ALL employees feel like
“they belong” and that all applicants interpret a dynamic
representation of the type of organization that you are.
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Techniques of Bolstering ActionOriented Programs
OFCCP Resources
Employment Resource Referral Directory (ERRD): http://www.dolesa.gov/errd/index.html
http://www.dol.gov/ofccp/regs/compliance/resources_recruit_disability.htm
http://www.dol.gov/ofccp/regs/compliance/resources_selfid.htm
http://www.dol.gov/ofccp/regs/compliance/resources_info.htm
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Techniques of Bolstering ActionOriented Programs
Veteran Outreach Programs
www.h2h.jobs/ *FREE
www.vetjobs.com
www.hirepatriots.com
www.hireherosusa.org
www.veterans.jobs
www.veteransoutreach.com
Disability and Veterans Community Resources Directory:
http://www.dol-esa.gov/errd/resources.html
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Techniques of Bolstering ActionOriented Programs
Disability Outreach Programs
www.business-disability.com/services *FREE
www.abilitylinks.org *FREE
www.earnworks.com
www.jobaccess.org
www.gettinghired.com
www.projecthired.org
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In
Conclusion
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Q&A
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