AFFIRMATIVE ACTION PROGRAM

Transcription

1 AFFIRMATIVE ACTION PROGRAM Office of Federal Contract Compliance Programs (OFCCP) Under Executive Order 11246For WOMEN AND MINORITIES Pima County Community College District 4905 E. Broadway Tucson, Arizona For the Period January 01, December 31, 2018 DUNS # EIN # A1 FICE Code # IPEDS Reporting EEO Contact: Kate Siemsen Walker Advanced Analyst EEO/ADA/AA Pima County Community College District 4905 E. Broadway Tucson, AZ (520)

2 SECTION I Responsibility for Implementation 41 CFR (a) Lee D. Lambert, Chancellor of the Pima County Community College District, has overall responsibility to implement the College s equal employment and affirmative action policy. The College has in turn assigned the responsibility to coordinate and implement that institutional policy to the Advanced Analyst - EEO/AA. This position has the full support and access to senior management officials, through the Office of General Counsel which reports directly to the Chancellor and the Governing Board. It has been and shall continue to be both the policy and the commitment of Pima Community College to further equal employment opportunities for all persons regardless of race, religion, color, national origin, sex, age, status as a protected veteran or status as a qualified individual with a disability. The College s EEO policy, as well as its affirmative action obligations, includes the full and complete support of the Chancellor, Lee D. Lambert, as well as the College community. 2

3 SECTION II Identification of Problem Areas 41 CFR (b) Pima Community College (PCC) conducted an analysis of the following personnel matters for the 12 month period January 01, December 31, PCC entered into its first federal contract requiring the preparation of an official Affirmative Action Program (AAP) effective August 1, The analysis for this report, January 01, December 31, 2017, primarily identifies forward actions the College will take in the AAP 2018 year to comprehensively meet federal contractor obligations. The PCC Human Resources (HR) department anticipated implementing a new Applicant Tracking System (ATS) in the plan year, however that process was administratively delayed. Current efforts will have that new system fully operational by the fall of Therefore, in the upcoming 2018 AAP year both Talent Acquisition and the EEO/AA offices will continue to work with multiple systems, including the existing ATS, PeopleAdmin, and the new system, Cornerstone ATS. EEO/AA will be involved in the design and implementation to maximize Cornerstone s capabilities to meet the data collection and AAP federal reporting requirements. PCC will continue to ensure that HR record-keeping practices and system structures are in place to support efficient and on-going self-auditing processes to analyze the following employment related activities: selection; recruitment; promotion, transfer and termination. PCC is still undergoing reorganization which has not been completed at the time of this document s finalization. The organizational profile outlined in 41 CFR , which is composed of an organizational display and is supplemented by a workforce analysis, is an ongoing process as PCC makes efforts to determine whether barriers to equal opportunity in any aspect of employment exists. In the years prior to 2014, under a voluntary AAP, PCC had undertaken the development of job groups in order to conduct a utilization analysis for purposes of identifying placement goals. A utilization analysis was conducted for this Affirmative Action Program document, the outcome will be used to advise recruitment efforts between January 2018 and December From the analysis, one faculty goal was identified in the area of Instructional Faculty - Writing, Job Group 371, where availability analyses indicated an under utilization of minority representation within the job group. The Provost Chief Academic Officer is responsible for the 3

4 recruitment and selection of faculty positions for the College. When this goal was identified, the EEO/AA office shared the information with that office, so appropriate efforts to insure a diverse and inclusive pool of applicants would be available for the on-going recruitment for a Regular Instructional Faculty Writing. From the availability analyses of staff/adminsterative job groups, one staff goal was identified in the area of Information Technology (IT) Support, Job Group 112C. This is the same goal that was identified in two previous plan years. There were two recruitments in this job group between October 01, 2016 and September 30, The recruitment pools did not contain a significant number of qualified female candidates, therefore PCC continues to have a goal in this job group. Human Resources- Talent Acquisition will make a more concerted effort to expand their outreach and recruitment efforts to attract qualified female applicants with the skills and abilities necessary to meet the duties and responsibilities of positions in this job group that may become available in the 2018 AA plan year. The establishment of a placement goal does not amount to an admission of impermissible conduct. It is neither a finding of discrimination nor a finding of a lack of good faith affirmative action efforts. Rather, the establishment of a placement goal is designed to be a technical targeting term used exclusively by affirmative action planners who seek to apply good faith efforts to increase, in the future, the percentage employment of females and minorities in their organization s workforce. The intent of the analysis is to support the College s HR-Talent Acquisition department, as well as the Provost s Office, in their recruitment efforts to meet federal guidelines. This is the third year that the college has done an Adverse Impact Analysis on all recruitment activity. Based on the statistical analysis there were no job groups identified to have had any issues or concerns. The College will continue to conduct appropriate statistical analysis on all recruitment processes to ensure that the recruitment efforts are in compliance with federal guidelines and meet contractor obligations. Although efforts have been on-going, the College needs to continue to strengthen the partnership(s) and cooperative efforts between the EEO/AA, IT, Faculty Recruitment within the Provost s Office, Diversity Officer, and all of the HR teams to meet the outreach, reporting, and monitoring obligations of the Affirmative Action Program. 4

5 SECTION III Development and Execution of Action-Oriented Programs 41 CFR (c) Action-oriented programs will continue to be developed and tailored to address any problems that may have been identified during the analysis conducted in preparation for the next AAP 2018 cycle. The EEO/AA Department staff will maintain ongoing interactions with the HR Department and the Provost s office, providing any necessary guidance on AAP reporting requirements. To produce an Organizational Profile as stated in 41 C.F.R (A), the College continues to work with the IT and HR Departments to extract information from the Human Resource Information System (HRIS) into the prescribed format. Some of the good faith efforts the PCC has routinely undertaken to support equal employment opportunity in recruitment, promotion and welfare within the PCC include: The College maintained its membership with Direct Employers to ensure compliance with outreach, listing, posting, and professional development. The College will update and expand its Social Media presence to broaden their outreach efforts. The College will create a greater presence in the community through notification of employment opportunities to traditional and non-traditional organizations and community outreach groups that serve women, minorities, veterans, individuals with disabilities, seeking to build and grow our outreach to a more diverse ethnic/racial population. The College encourages all employees to refer applicants. The College actively participates in local and regional job fairs. Except in rare cases, all regular, promotional, acting and transfer opportunities are posted internally, externally, and/or both. 5

6 All recruitment processes will continue to be monitored to ensure that the recruitment efforts are in compliance with federal guidelines and meet contractor obligations. EEO/AA will continue to work cooperatively to strengthen the partnership between the EEO/AA, IT, Faculty Recruitment within the Provost s Office, the Diversity Officer, and HR teams to meet the outreach, reporting, and monitoring obligations of the Affirmative Action Program. Effective in January 2018, all employees including hiring managers, participating on Selection Advisory Committees (SACs) will be required to complete five online Unconscious Bias trainings. The purpose of this training is to assist with understanding how biases can contribute to decision-making, most notably with regard to recruitment and selection. Therefore, only those who have completed the unconscious bias series listed below will be permitted to serve in the selection and hiring processes. HR- Organizational Effectiveness and Development will be responsible for tracking and maintaining documentation of the completed course work of each individual. The data will be made available and included in the 2019 AAP. The five online courses are: Guarding Against Interviewing Biases Overcoming Unconscious Bias in the Workplace Understanding Unconscious Bias Overcoming Your Own Unconscious Bias Applying Your Best Thinking. Direct support and Ad Hoc training will be available to hiring managers to ensure they are in compliance and meeting the guidelines of the federal contracts, as well as ensuring that the process remains compliant and non-discriminatory. Training will made available from outside vendors and/or professional organizations for the facilitators who will be conducting the training. 6

7 SECTION IV Design and Implementation of Internal Audit and Reporting Systems 41 CFR (d) The EEO/AA Advanced Analyst is responsible for the development and coordination of systems required by federal guidelines and under Federal Contractor obligation. In conjunction with the above referenced responsibilities, the College created a new Regular Part-time position, Human Resources Analyst, assigned to provide direct support to the AAP. This dedicated position adds stability and continuity for the development, management, coordination, and on-going analysis of systems required as detailed by the federal guidelines. The EEO/AA HR Analyst prepares reports and analyses on all recruitment activities and makes the data available to the EEO/AA Advanced Analyst on an ongoing basis. This Unit will continue to work directly with related departments, teams, and sections in the implementation of a more efficient and comprehensive reporting and monitoring system that will provide for: 1. Review of the applicant tracking system of all referrals, applicants, hires, promotions, and transfers by race and sex to be certain that all employees/applicants are treated on a fair and equitable basis. 2. Review of all selection, promotional and training processes to ensure that they are nondiscriminatory. 3. Implementation a compensation classification and compensation analysis. Development and submission of recommendations to top management for improvements and changes, as necessary. 7

8 SECTION V Organization Display/Workforce Analysis 41 CFR Pursuant to 41 CFR Pima Community College will provide either an Organizational Display or a Workforce Analysis for the 2018 Affirmative Action Plan. 8

9 SECTION VI Job Group Analysis 41 CFR Overview Pima Community College (PCC) is committed to equal employment opportunity and will continue to actively seek and recruit a qualified and diverse pool of applicants for all job postings. This section contains the parameters applied to the job group analysis and availability analysis. Together these form the utilization analysis that is used to identify whether areas of under-utilization exist. PCC has established a one-year timetable during which it will make good faith efforts to focus on the recruitment and referral of qualified minority and female applicants for all position recruitments in job groups identified with availability higher than current utilization after applying the 80% rule. This rule states if current utilization is equal to 80% or more of availability, then a goal is not identified. Utilization details are maintained under separate cover. Job Group Analysis Higher education environments are one of the most complex organizational structures in which to apply regulation guidance for job groups. Regulations guide the employer to develop job groups that are statistically significant, typically or more employees, for analysis. However, in an effort to meet this regulatory guidance, job titles with distinctly different qualifications would need to be combined. This approach would not produce an accurate estimate of availability. Staff and administrator job groups were analyzed when there were 30 or more employees in that specific job group. Regular faculty positions have specific annual recruitment cycles. Only approved recruitments for specific disciplines are utilized in the analysis. Therefore, the design of the job groups is based on the following logic: For both Instructional Faculty and Educational Support Faculty, the specific academic discipline area is the criteria applied. For administrative and staff job groups, the more distinct knowledge, skills, abilities/credentials, and/or job titles are the criteria. This design results in small job group sizes due to uniqueness of the job requirements especially in the faculty disciplines. A list of all job titles assigned to each job group is maintained. The job group structure will be expanded and revised as needed. 9

10 Availability Analysis To determine female and minority availability for a job group the College compares the availability of external qualified females and minorities for employment in each job group with the appropriate incumbent qualified workforce in each Job Group. This results in a determination of whether or not the job group is underutilized. Two Factor Analyses The following two factors are considered under federal regulations when conducting availability analysis. 1. Percentage of minorities and women among those having the requisite skills, in a reasonable recruitment area. Most often this factor is based on 2010 U.S. Census data or the most recently available IPEDS staff survey report. 2. Percentage of minorities and women within the facility/institution whoare promotable or transferable. Relevant internal feeder job groups are identified for this factor based on the most recent history of promotions into a job group. Additional Relevant Components In addition, an employer may include other relevant factors in its analysis. The composition of any recent recruitment pools within the job group may be factored into the availability analysis. Data provided by recent reports (IPEDS) provided by the National Center for Education Statistics are also considered in the analysis. The availability analysis for each job group will involve two to four of the indicated factors. Administrator Positions PCC recruits nationally for all administrative positions. National U.S. Census statistics are considered for Factor 1. However, since there are no relevant job titles in the census data for higher education administrators, the 2011 IPEDS report - Executive/Administrative category was used instead for Factor 1. Over the past 10 years, Instructional Faculty has been a key feeder group for the Administrator job group. Therefore, the statistics from the current composition of women and minorities as regular full-time Instructional Faculty were used for Factor 2. 10

11 The composition of qualified candidates in the Administrator applicant pools over the past year was the basis for the development of a Factor 3. No goal was identified for the Administratrator job group; the college utilization exceeds availability. Exempt and Non-exempt Positions Exempt positions are posted on the PCC website; historically, state-wide recruitment efforts have been targeted. Arizona State U.S Census statistics are generally used for the reasonable recruitment area for Factor 1. Non-exempt positions are posted on the college website and are historically filled from the local Tucson area. The Pima County 2010 U. S. Census metropolitan statistical area (MSA) statistics are used for Factor 1. Factor 2, for both exempt and non-exempt positions, is comprised of the current statistical composition of the relevant internal feeder job group, if one is available. Factor 3, for both exempt and non-exempt positions, is based on an analysis of the recruitment pool of qualified applicants for job titles in the job group over the past 12 months. This year a placement goal for females was identified in the IT Support job group 112C with all of the other job groups meeting or exceeding placement goals based on availability. Faculty Availability analysis was conducted for the faculty positions approved for recruitment during the academic year, with positions beginning July 1, 2018 at the earliest. Positions approved for recruitment are the only faculty positions for which a good faith effort can be made to improve representation. PCC conducts national recruitment for all faculty positions. The 2010 National U.S. Census data for All Higher Education Instructors was considered for Factor 1. A subset of Factor 1 included the consideration of appropriate 2010 National U.S. Census occupational code data for disciplines such as Administration of Justice, Art/Photography, Aviation, Drama/Theater, Librarians, Mechatronics, and Music. The minority and female composition of adjunct faculty by discipline for the previous Fall 2017 semester was used to calculate Factor 2. 11

12 The composition of qualified minority and female candidates in relevant and available faculty applicant pools over the last two years was used to calculate Factor 3. Most of the faculty job groups currently open for recruitment are too small (under 30 employees) for meaningful analysis to determine whether a goal can be identified. Mathematics and Writing were the only recruitments that were large enough for a meaningful analysis. No goal was set because the utilization equals 80% of availability for Mathematics, however, a goal was identified for Instructional Faculty Writing (Job Group 371), where availability analyses indicated an underutilization of minority representation within the job group. Based on the analysis of the utilization factors, this was the only goal identified for approved regular faculty job group recruitments. Placement Goals - Utilization Analysis Placement goals are established when underutilization is identified during the availability analysis. Underutilization, as defined by federal regulations, means having fewer women or minorities in a job group than might reasonably be expected given their availability. A goal does not need to be established if utilization equals 80% of availability. As stated previously in the plan, the establishment of a placement goal does not amount to an admission of impermissible conduct. It is neither a finding of discrimination nor a finding of a lack of good faith affirmative action efforts. Rather, the establishment of a placement goal is designed to be a technical targeting term used exclusively by affirmative action planners who seek to apply good faith efforts to increase, in the future, the percentage employment of females and minorities in a workforce. 12