ARE YOU AN AFFIRMATIVE ACTION EMPLOYER?

You are an Affirmative Action Employer if you have:

• Federal contracts or subcontracts worth $10,000 or more
• OR have 50 or more employees and contracts worth $50,000 or more
• OR are a construction contractor or subcontractor with a federal or federally assisted contract valued at more than $10,000.

If you are an Affirmative Action Employer -
You may be covered by Executive Order 11246, the Rehabilitation Act of 1973, and the Vietnam-Era Veterans’ Readjustment Assistance Act and Jobs for Veterans Act.  This requires you to have a written Affirmative Action Plan according to the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP.)  You may also be subject to “EO surveys” from the government, compliance checks, compliance reviews (at your workplace), and “glass ceiling” audits at your corporate office.

CEA Can Help!
The California Employers Association partners with our sister organization, The Employers Association, to complete your affirmative action plan.  The Employers Association has over 20 years of experience in assisting members throughout the country with the design, documentation, implementation, and update of their Affirmative Action Plan (AAP.)  In the last year, they wrote more than 120 plans and assisted in several OFCCP compliance reviews. 

CEA can assist your department with a complete written plan including, narrative, workforce and job group analysis, availability and utilization analysis, and adverse impact analysis.  Staff members can also aid in compensation analyses as well as compliance reviews and checks.  We have a compliance assessment to assist HR professionals perform mock audits and make recommendations to individual companies in preparation for OFCCP desk audits. 

To assist employers with affirmative action plans, CEA uses knowledge, experience, and a fully integrated, customized Computer Assisted Affirmative Action Plan (CAAAP) program.  It uses externally supplied census occupation data and employer provided workforce data to produce two-factor Availability and Utilization Analyses. The reports are suitable for inclusion in the final copy of your AAP.

What is included in Affirmative Action Plans from CEA?

• Work Force Analysis:  A snapshot of the workforce by department or organizational unit, which includes job title, race and gender breakout, and salary or wage code. 

• Availability Analysis (Two Factor Analysis):  The process that estimates how many minorities and females are available for employment.  The percentages produced by this analysis are benchmarks against which the employer’s utilization of females and minorities is measured.

• Utilization Analysis: The comparison of availability to workforce composition of minorities and females for each job group. The comparisons are made using a variety of rules, such as the 80% rule, the Any Difference Rule, and the 2 and 3 Standard Deviation Rule. The result indicates instances of underutilization of minorities or females within a job group.  With CAAAP we combine and weigh data from different geographic areas to create custom areas that match your specific recruiting patterns. 

• Impact Ratio Analysis (Adverse Impact Analysis):  The analysis measures the rates at which females and minorities are selected for employment decisions.  Adverse impact is indicated when there is a substantial unfavorable difference in the selection rate of these groups.
  
  
• Written Narrative:  A document that contains the required implementation procedures and language essential to regulatory compliance.
  

• Compensation Analysis:  included in the workforce and job group analyses, is compensation information.  It is a requirement to review compensation each year to make sure that there is no systemic discrimination present in the workforce.  It is the company’s decision as to how to analyze the compensation and what methods to use.

• Audit Assistance:  If contacted for a desk audit by the OFCCP, CEA will assist in gathering the required information to send in for review. 

Affirmative Action Price List