AAP - Setting Goals

jules2001

Hi all - I thought I would come to the "experts" for help with this one. We have recently met the requirements of the need for an AAP. We have determined underutilization, etc. I am at the point where I need to set the goals. What is the verbage that you use when putting these goals on paper?

LFernandes

[font size="1" color="#FF0000"]LAST EDITED ON 02-27-03 AT 01:23PM (CST)[/font][p]

jules2001

Well, I am just not sure what words to use to state my goals. I have been told that I have 2 positions where we are underutilized. On of them is management and we have no plans to even do any hiring in this area. Does my goal just say "If hiring is done for this position and all things being equal we will hire to fulfill the underutilization"? See, that just counds corny. I am just not sure what the words should be or should attempt to say. I have never had to deal with AAP before. Thanks for everyone's help.

Gillian

No, you say that you do not anticipate any hiring in this job group but that if there are changes that you will make a good faith effort to recruit qualified individuals for any position that opens up.

jules2001

Thanks Gillian - that sounds so much better and makes much more sense.

Don D

And don't come off sounding like a 'promise to do this or that'. The regulations that require AAP processes do not place upon you a legal (or otherwise) obligation to fill positions with certain categories of persons. AAPs should not appear to be hiring-quota statements. Unless I'm mistaken, The AAP should be a snapshot of your workforce demographics as compared to representative data of what exists in the labor market area and it should state or imply your company's understanding of how those two mesh or don't mesh as well as your objectives for addressing notable, controllable areas of misalignment. I struggled with that last word. I need someone to suggest a better one.

vmiller MO

In developing an AAP, I suggest that you refer to the regulations. 41 CFR Section 60-2.16(c) states "[When a contractor] is required to establish a placement goal for a particular job group, the contractor must establish a percentage annual placement goal at least equal to the availablity figure derived from women or minorities, as appropriate, for that job group." It has been my experience that the OFCCP takes these words literally. If, for example, availability figure for women in a particular job group is 35% and your company has 10%, then your goal is to have women in that particular job group at 35%. At this point in the analysis OFCCP doen not care that you are not hiring. That is the goal. When you don't reach the goal during the plan year, then you state that you did not achieve the goal because the company did not hire anyone or that you downsized, etc. There really is not flexibility as to what the goal should be.

Good luck.

jules2001

So using the example above, the goal would be "make a good faith effort to increase number of females in job group to meet or exceed the 35% requirement"? From the other responses, that seems incorrect because it sounds like a promise or may not be attainable. I have also read/heard that you cannot continue to use same goals if you do not meet them. If we do not hire, we do not meet them, then what? Sorry, this whole thing is just a bit confusing. I have the AAP completed by corporate, per requirements, except for the goals, this part has been given to me.

ray a

Last summer I completed my fourth AAP and just recently successfully passed a DOL audit of our most recent AAP. For the goals, we have a chart listing each job group, the availablity for each catagory, the minority actual and the female actual. Where the actual is lower than the availability that difference becomes aour goal. In the verbiage I stated that we had made some gains (which we had) in hiring and promoting women, particularly in key positions. And we will continue to make good faith efforts. I understand the DOL is looking for the "good faith efforts" backed up by measureable gains.

I'm far from an expert, but have survived aa audit.

Gillian

I think that we are talking about two different things. In the chart that ray a references there is a place to put your goal for each job group. That remains the overriding goal and reflects the analysis of the labor market. In the narrative, which was the original question, the writing should reflect what you hope to do in the coming year. It could be nothing (no hiring expected)to making a good faith effort to increase by "x" based on expected turnover. In the following years narrative you explain how you did, or did not, meet the goals that you described.

jules2001

Thanks to everyone for your replies. As usual, it has helped alot. I really appreciate that I can always depend on the wonderful folks on this forum to help with my confusions. x:-)