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New Regulations-Statistical Changes

The new regulations require that each Affirmative Action Plan must contain a statistical analysis of employees as of the beginning date of your current plan. This data must be presented in the following required reports:
Workforce Analysis or Organizational Profile, and Annotation
Job Group Analysis and Annotations
Availability Analysis (see 2 factor analysis below)
Placement Goals (formerly referred to as underutilization)

The new regulations also provide for an extension of the "Corporate Initiative." This means that:
Employees working at establishments other than that of the manager they report to must be included in the AAP of their manager.
Employees for whom selections decisions are made at a higher level in the organization, must be included in the AAP of the establishment where the selection decisions are made.

Employers who have a location covering less than 50 employees must include those individuals in:
a separate AAP covering that location;
the AAP of the location providing the human resources function;
the AAP covering the location of the manager where they report

Two Factor Analysis

The new regulations have done away with the eight–factor analysis required as part of the availability and utilization reports. Essentially OFCCP has eliminated the old Factors 1, 2, & 3. No one was using them anyway, so this is of little consequence. The new two Factors are:
The percentage of minorities or women with requisite skills in the reasonable recruitment area
The percentage of minorities or women among those promotable, transferable and trainable with the company

These changes require a complete revision of the reports that are prepared for your Affirmative Action Plan. Our proprietary software will complete each report in a format that will pass OFCCP compliance audits.

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