Employers that implement and fully embrace an Affirmative Action Program understand that it can be an effective management tool instead of just a paperwork distraction. These employers move beyond the basics of the regulatory requirements and integrate the program into their workforce management strategy.
In truth, your Affirmative Action Plan (AAP) should be considered a business plan for each manager. This action plan should include four elements:
- An initial assessment of each component of an organization
- Identification of problem areas
- A set of goals
- A periodic progress report against those goals.
This is true of your AAP for women and minorities but perhaps even more critical for individuals with disabilities (IWD) and veterans. OFCCP expects organizations to measure their progress (or lack of) in meeting their goals and modifying their strategy when insufficient progress is made.
How to Define Managers’ AAP Goals
One of the keys to incorporating an Affirmative Action Program into your workforce management strategy is getting buy-in from your management team. The program must be developed so that it becomes a useful and effective tool for your managers. And the executive management team must clearly demonstrate commitment to the program and hold each member accountable to meeting the goals defined in for your program.
As part of this commitment, organizations need to include AAP goals in their manager’s annual performance review. Each manager’s annual performance must be evaluated based on achieving their AAP goals, and annual merit increases should be impacted based on achievement of those goals.
Smart employers understand that managers require AAP goals that are reasonable, relevant, and attainable. The goals must be based on a process that produces targets in alignment with the
- Manager’s areas of responsibility
- Race / gender / ethnicity demographics of the workforce they manage
- Skill set of their workforce.
Targets must be relevant and attainable, otherwise you risk losing buy-in and commitment. This is especially true if compensation is affected by managers’ ability to meet AAP goals.
While it may seem appropriate to develop manager-level targets by starting from corporate-level goals and using a simple average or weighting methodology, in reality this approach is insufficient and not supportable. Goals calculated in this way cannot be statistically supported and often undermine your Affirmative Action Program.
Rather, a manager’s organization must be analyzed on its own, as if to develop its own AAP. Examine each manager’s workforce via a fully detailed incumbency versus availability analysis. This means using a relevant mix of occupational categories, labor area demographics, and relevant weighting of internal and external factors to arrive at attainable placement goals.
Go Beyond OFCCP Goals to Measure ROI of Affirmative Actions Programs
Employers commonly use predefined goals for IWD and veterans AAPs as defined by the OFCCP. But here again, progress towards these goals should follow the same approach described above.
The OFCCP also expects organizations to develop and track results on investment (ROI) when it comes to goals for IWD and veterans. So employers must hold each individual manager accountable and provide frequent and regular feedback on progress.
By providing reports on a regular schedule, your compliance team can empower managers with data-driven insights to adjust their business practices accordingly throughout the year. Similarly, your team should provide progress reports a frequent and regular basis to executive management.