In light of the OFCCP’s revised scheduling letter which in part requests a contractor’s definition of a promotion, we want to ensure that you are prepared with a definition, that you are applying the definition consistently in your promotion activity, and that you are maintaining data which supports your definition.What constitutes a promotion?Although the definition of a promotion varies from contractor to contractor, generally, a promotion is considered a personnel action that may result in one or more of the following:
- Movement to a position affording higher pay and/or greater rank
- Movement to a position requiring greater skill or responsibility
- Movement to a position that affords the opportunity for upward mobility
On the other hand, the following actions would typically not be considered a promotion:
- Standard pay increases (based on annual performance reviews and/or cost of living adjustment)
- Job title changes without increase in pay or responsibility
The importance of consistency and support data:Based on the new scheduling letter, in an audit, the OFCCP will review your actual promotion activity and will compare it against the definition you provide. Any inconsistencies in applying the definition to your promotion decisions would raise a red flag and result in further scrutiny and investigation.
If you have questions about a promotion in your company or need assistance reviewing your data please contact Career Resources at email@example.com. We would be happy to assist you with any of your Affirmative Action Plan needs.