Attendees will receive a general overview and explanation of the sources of authority and resulting obligations requiring covered employers to take affirmative action in employment. Attendees will also be given specific instruction with regard to the key ingredients of a written affirmative action plan and other affirmative action obligations, including the completion of adverse impact analyses for employment practices. Finally, attendees will learn about the OFCCP's enforcement powers and how to successfully prepare for and respond to an OFCCP audit.
- Preparation of an Executive Order 11246 AAP
- Top 10 mistakes in preparing an Executive Order 11246 AAP
- Developing job groups that make sense
- Developing proper adverse impact analyses
- Protecting AAP information from discovery
9:00 a.m. - 9:15 a.m.
I. Introduction And Seminar Overview
9:15 a.m. - 10:45 a.m.
II. The Basics: Who Is Covered By What And Why?
A. Sources Of Authority
B. Who Is Covered?
C. Subcontractor Issues
D. Threshold Coverage vs. Obligation To Have A Written Plan
E. Basic Requirements Of A Written Affirmative Action Plan
10:45 a.m. - 11:00 a.m.
11:00 a.m. - 12:30 p.m.
III. Tracking Data/Who Is An Applicant?/Why Does It Matter?
A. Proper Data Tracking For Hiring, Promotions And Terminations
1. Who Is An Applicant? (A Discussion Of New EEOC Guidance)
2. Promotion Data
3. Termination Data
B. Completing Proper Adverse Impact Analysis
1. What Is The Proper Availability For Comparison?
2. What Is 'Adverse Impact'?
3. A Word On Confidentiality
12:30 p.m. - 1:30 p.m.
Lunch (On Your Own)
1:30 p.m. - 3:00 p.m.
IV. Utilization Analysis/Organizational Profile
A. Proper Preparation Of Utilization Analysis
1. Proper Formation Of Job Groups
2. What Is The Proper Availability For Comparison?
3. Setting Placement Goals
4. Good Faith Efforts And Programs
B. Proper Preparation Of Organizational Profile
1. The Difference Between Organizational Units vs. Job Groups
2. Organizational Display vs. Workforce Analysis
3:00 p.m. - 3:15 p.m.
3:15 p.m. - 4:15 p.m.
V. Other Affirmative Action Obligations/Enforcement
A. Other Affirmative Action Obligations
1. Executive Order 11246 Obligations
2. Obligations Under Sect. 503
3. Obligations Under VEVRA
B. OFCCP Enforcement
1. Desk Audits
2. On-Site Reviews
3. Other Enforcement Mechanisms
4:15 p.m. – 4:30 p.m.
VI. Questions And Answers