What is a Promotions Focused Review?

In recent decades, women and minorities have made incredible strides in the workplace.

Government policies and corporate initiatives have increased their employment rates. Workplace equality efforts have also supported pay equity.

At the same time, though, women and minorities still lag behind white men in promotions. In 2020, white men continued to represent 90% of Fortune 500 CEOs.

The promotions focused review seeks to end this glass ceiling among federal contractors.

Learn more about it in this expert guide.

What Is a Promotions Focused Review?

The Office of Federal Contract Compliance Programs (OFCCP) implemented the promotions focused review in 2018. It targets workplace policies related to promotions.

The OFCCP defines promotions as personnel decisions that lead to:

  • Higher pay
  • Higher rank, title, or job grade
  • Greater responsibility or required skill

Promotions can be competitive or not. In all cases, though, promotions must be inclusive advancement opportunities. 

The OFCCP recognizes that policies and procedures can enhance or impede workplace equality. This is especially true for advancement opportunities.

Thus, the promotions focused review works to identify and address discrimination. It also ensures that employers work actively to achieve equality at all levels.

Who Is Subject to Promotions Focused Review?

The OFCCP governs the workplace policies of contractors and subcontractors under three laws:

  • Section 503 of the Rehabilitation Act
  • Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA)
  • Executive Order 11246

Federal contractors and subcontractors are bound by these laws. Thus, they are subject to OFCCP audits.

Contractors scheduled for an OFCCP audit will receive a scheduling letter.

Contractors cannot be scheduled for another audit while a focused review is pending. Still, the OFCCP will continue to investigate complaints if they arise.

What Happens During a Promotions Focused Review?

Promotions focused reviews include two parts:

  • A desk audit
  • An on-site investigation

These efforts involve an in-depth look at a contractor’s policies, procedures, and data. 

Policies of particular concern to the OFCCP are those related to:

  • Employee evaluations
  • Selection procedures for promotions
  • Internal and external candidate recruitment procedures
  • Outreach efforts

Relevant data includes hiring and compensation statistics and personnel files. It also includes the company’s Affirmative Action Plan (AAP).

During the on-site visit, OFCCP officers will supplement the data with interviews. 

Managers responsible for advancement decisions can expect to speak to compliance officers. OFCCP officials will also interview employees affected by promotions policies.

Finally, during a promotions focused review, the OFCCP will suggest areas for improvement. It will also educate contractors on best practices. This guidance can help contractors not only meet but exceed requirements.

How Can Contractors Prepare for Promotions Focused Review?

A contractor’s efforts to complete an audit must begin before one is scheduled.

In fact, compliance requires ongoing efforts to write, monitor, and update an AAP. Contractors must share the content of their AAPs with the OFCCP when requested.

Contractors must also conduct in-depth internal assessments of their own policies. They must share the results of these assessments with the OFCCP during a focused review as well.

Promote Equality—and Your Company’s Success—with an AAP Consultant

Now that you’ve read this article, you understand the OFCCP promotions focused review. Perhaps, though, you still have questions. For example, you might be wondering, “What is an affirmative action plan?”

Whether you need help with an audit, your AAP, or both, Career Resources Inc. can help. Contact us today to learn how.

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