TMA can assist your organization in developing and/or reviewing your affirmative action plans to meet all the requirements of the Office of Federal Contract Compliance Programs (OFCCP). Our experienced, knowledgeable staff will relieve your company of the annual staffing overload and concern about information processing to meet your compliance requirements. The OFCCP is now conducting spot checks to insure contractors are completing their affirmative action plans and all required reporting. Contractors are sometimes given short notice of an OFCCP visit, so it’s important to have an updated, compliant plan. Affirmative Action Plans (AAPs) must be produced and updated annually. The plan year can be a calendar year plan, fiscal year plan, or any date the contractor chooses. The three parts of a compliant affirmative action plan are: Written - This includes standard language that meets all regulatory requirements, the minority/female plan text and the veteran/disabled plan text. Statistical - This analysis is performed at the beginning of each plan year and compares the workforce at each location to the recruitment pools (internal, local recruitment area and total recruitment area). Statistical analysis documents where a location is under-represented and provides goals based on this analysis. Goal Attainment - Here we evaluate the number of opportunities in each job group (hires plus promotions) and calculate percentages to determine if goals are met. All outreach efforts will be reviewed and modified as necessary.

Who Must Develop and Update Affirmative Action Plans?

For Minorities and Women Each non-construction (supply and service) federal government contractor (and subcontractor) must develop and maintain a written affirmative action program for each of its establishments, if it has 50 or more employees and: Has a contract of $50,000 or more; or Has government bills of lading which in any 12-month period total or can reasonably be expected to total $50,000 or more; or Serves as a depository of government funds in any amount; or Is a financial institution which is an issuing and paying agent for U.S. savings bonds and savings notes in any amount. For Disabled and Veterans Any employer with a contract value or purchase order from the federal government worth $10,000 or more or any employer with bills of lading of $10,000 or more in 12 months must develop and maintain a written program. If you are required to develop any of these affirmative actions plans, TMA will prepare a high quality and accurate plan for your business.

Developing Your Affirmative Action Plan

TMA can prepare an affirmative action plan in weeks and require minimal time from your staff. Your staff’s role is to provide an organization chart and employee information in spreadsheet form on a template provided by TMA. We will work together to determine your organization’s policies and practices concerning affirmative action and to ensure your organization is making every effort to be in compliance. We can also provide support during a stressful OFCCP compliance review.

The Affirmative Action Plan for Minorities and Women

Our plan contains all the required elements, including: Confidentiality and Preliminary Statements Designation of Responsibility Identification of Problem Areas Workforce Analysis Job Group Analysis Compensation Analysis Availability Analysis Utilization Analysis Placement Goals Action-Oriented Program Internal Audit Reporting Systems

The Affirmative Action Plan for Veterans and the Disabled

This plan includes all the required aspects of the AAP. Among the elements included are: Equal Employment Opportunity Policy Dissemination of the Policy Outreach and Positive Recruitment Reasonable Accommodation Complaint Review Procedure Provision for annual review of personnel policies and practices, and physical and mental job requirements Subcontracts Responsibility for Implementation TMA can prepare one plan which meets the requirements of the OFCCP for each target group.

Reports Included in Your Plan

Job Group Analysis If not already established, we will help you create job groups. Job groups are comprised of jobs with similar duties, pay and promotional opportunities. Organizational Profile or Workforce Analysis The organizational profile is a detailed organization chart that identifies each organization unit and the relationship between units. To perform this profile, we need to know which employees are supervisors. The preferred analysis is a workforce analysis which ranks job titles by department on the basis of race, sex and wage grade. Availability Analysis For each job group, we perform a two-factor availability and corresponding utilization analysis, which compares the availability of employees in the recruiting areas to the composition of your workforce. We also determine if one group “feeds” another. For example, a group of entry level clerical might be a feeder group for mid- or upper-level secretarial slots. We then assign weights to each factor for each job group. Utilization Analysis After computing availability percentages for each job group, we will determine if any job groups are underutilized. Underutilitzation means there is a significantly lower proportion of minorities and/or females in your workforce than would be expected, based on availability. Where we find underutilization, we set an informal target percentage equal to the availability. Narrative Sections TMA will write the narrative sections of your plan. We will discuss the results of the statistical analysis with you and prepare our position statements based on those discussions. You will be asked to provide copies of policies, postings, recruitment letters, etc., to include in the plan. Once completed, we will prepare a notebook for each plan facility. Compensation Analysis TMA will analyze your compensation system using the technique most often used by the OFCCP - the Dubray Analysis. We produce reports showing areas that the OFCCP will most likely scrutinize, giving you time to focus on them now. Many times differences in pay can be explained due to seniority, merit, etc. In other cases, pay may need to be adjusted. Information needed for this analysis includes hire date, annual salary, job date, and if available, salary grade. Adverse Impact Analysis The annual adverse impact analysis compares the selection rates for minorities and females to the selection rates for non-minorities and males for all employment activities, including hires, promotions/transfers, and terminations. To perform this analysis we will need lists of all employment activity for the prior year.

Plan Implementation

Once your plan is completed, TMA can help you create an action-oriented program to achieve affirmative action goals. This includes outreach and targeted recruiting strategies, as well as developing effective internal programs such as mentoring, succession planning and career development.

Training

It’s important to train your managers and supervisors when the plans are introduced or updated to insure that they know their responsibilities under the plan. Affirmative action is a complex topic; managers need to be educated about what it is, why they have a plan, etc. TMA has an effective training program that covers topics necessary to thoroughly implement your affirmative action goals.

For more information

Contact Mike Moore at mmoore@wciinc.org.

TMA, Inc
2018 Electric Road SW
Box 230
Roanoke, Virginia 24018
Toll Free 1-800-621-2685
Direct 540-342-7881
Toll Free Fax 1-877-828-8110
Email freese@tmava.com