As the regulatory landscape for federal contractors becomes more grueling to traverse and OFCCP audits become more invasive, companies need to ensure, now more than ever, that their managers clearly understand what their affirmative action obligations are. To assist human resource teams with guidance on getting their managers “onboard” and involved with their AAP, we have listed five tips that may help:
- Start by informing managers that the company is a federal contractor and what this means in terms of regulations, i.e., the requirement to prepare and maintain an Affirmative Action Plan (AAP).
- Educate them on who the OFCCP is. This should include the OFCCP’s jurisdiction to conduct audits, how invasive these audits are, the manager’s obligations, accountability, and speaking part during an audit. Managers need to know that their employment decisions directly impact the outcome of an audit and that non-compliance could lead to administrative and/or financial penalties or debarment as a federal contractor.
- Disseminate your AAP, not the entire AAP, but sections that pertain to them. Include areas of underutilization, progress toward prior year goals, selection disparities, and pay disparities. Ensure that they know that it is “their” plan and they directly impact the success or failure of the AAP. Good intentions don’t count; the numbers are what are important!
- Ensure that managers understand the importance of keeping their job descriptions up to date and how job descriptions are used in an audit.
- Don’t wait until the end of the year to review plan goals, review goals quarterly and address any outreach, hiring, promotion, or pay disparities that you have identified and the financial impact of not correcting them.
CRI provides onsite and virtual training for HR and management teams; if you are interested in having CRI provide training for your company contact us at firstname.lastname@example.org