Affirmative Action Planning Hurdles

There are three primary hurdles to overcome/work through when preparing an AAP, according to Berkshire:

  1. Understanding OFCCP Requirements,

  2. Gathering the necessary data, and

  3. Implementing the AAP Across the Organization.

The first step above is the most legal-intensive, involving understanding definitions and requirements for the following:

  • Minorities and Women

  • Individuals with disabilities (IWD) and protected veterans (PV) · Placement goals and good faith outreach

  • Internet applicant and other affirmative action requirements

  • Communication and Implementation · Preparing for an OFCCP audit and the new Item 19 requirement

The second step is the most labor-intensive, assembling the data for each of the above.

The third step, then is developing a plan and goals to implement the AAP that has been developed. “Window dressing” will not suffice, because OFCCP does in-depth analyses during audits that will generally surface any discrepancies or compliance failures.

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