Preparing Your Data for AAP Development and Possible Audit Part I: Data Preparation

Transcription

1 Preparing Your Data for AAP Development and Possible Audit Part I: Data Preparation A presentation of the BCG Institute for Workforce Development (BCGi)

2 Biddle Consulting Group Inc. Affirmative Action Plan (AAP) Consulting and Fulfillment Thousands of AAPs developed each year Audit and compliance assistance myaap Enterprise software HR Assessments Custom Test Development & Validation EEO Litigation Consulting /Expert Witness Services Compensation Analysis Publications/Books BCG Institute for Workforce Development Speaking and Training AutoGOJA online job analysis system TVAP test validation & analysis program CritiCall pre-employment testing for 911 operators OPAC pre-employment testing for admin professionals Video Situational Assessments (General and Nursing) High stakes test development Validation studies in response/prevention to litigation Over 200+ cases in EEO/AA (both plaintiff and defense) Focus on disparate impact/validation cases Proactive and litigation/enforcement pay equity studies COMPare compensation analysis software EEO Insight : Leading EEO Compliance Journal Adverse Impact (3 rd ed.) / Compensation (1 st ed.) 8,000+ members Free webinars, EEO resources/tools Regular speakers on the national speaking circuit

3 Biddle Consulting Group Institute for Workforce Development BCGi Memberships (free): ~8000+ members / 18,000+ HRCI credits to-date Online community Monthly webinars on EEO compliance topics EEO Insight Journal (e-copy) BCGi Platinum Membership (paid) Includes validation/compensation analysis books EEO Tools including those needed to conduct AI analyses EEO Insight Journal (e-copy and hardcopy) Access to the BCGi library of webinars, training materials, and much more

4 A few housekeeping items:

5 Contact Information Biddle Consulting Group, Inc. (BCG) 193 Blue Ravine, Suite 270 Folsom, CA Tony Mentessi ext. 132 Marife Ramos, PHR, SHRM-CP ext. 129

6 Agenda: Part I Who s Included in the AAP? What Data do I Need? What goes into Determining my Availability? In Conclusion: Summary, Questions and Answers

7 Who s Included in the AAP?

8 Who s Included in the AAP? Which employees are included? Each employee in the contractor s workforce Who are employees? The term employee is broad enough to include part-time, temporary, and full-time employees Are they on your payroll as of snapshot date (one day in time)? Field employees roll into manager s location move up the chain

9 Who s Included in the AAP? Identifying the Corporate Initiative Employees: Organizations are required to identify employees who work in one AAP location while being on the payroll at another AAP locations and/or report to a manager at another AAP location. Employees who physically work at a given location will have to appear in the Workforce Analysis of that physical location (with annotation); but nowhere else in that AAP. The employees who report to another location are included in all AAP reports of that other location.

10 How to Define Corporate Initiative Employees: Recommendations: Who s Included in the AAP? Include Employees in the AAP of their supervisor or Those who are in certain levels (e.g., Executives, pay grade, etc.)

11 What Data do I Need?

12 What Data do I Need? An Affirmative Action Plan is a set of goal oriented management policies and procedures designed to identify and eliminate barriers to employment opportunities. By evaluating diversity in an organization s workforce and ensuring personnel processes/procedures are fair to all, we get a better understanding if any impediments exist. This is accomplished by taking a look at the organization at a single point in time and analyzing everything that has occurred over the past 12 months

13 What Data do I Need? Data Requirements to Complete an AAP: Employee Data As of a specific date (snapshot date) in time Example Using 12/31/2016, we want to capture all employees on the payroll as of this date. Transaction Data Applicants, Hires, Promotions, and Terminations that occurred during the 12 months prior to the selected snapshot date Example Using 12/31/2016 as the snapshot date, we would pull all transactions that occurred between 1/1/2016 and 12/31/2016.

14 What Data do I Need? Employees File Employee Identifier A unique identifier for each employee (e.g., Last four digits of SSN) Hire Date The date the employee was hired Gender Sex of employee (M/F) Race Employee s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran Employee s veteran status (Y/N) Disability Employee s disability status (Y/N) Job Code The code assigned to each unique job title Job Title The title of the employee s job Job EEO Category The EEO Category for the job title Salary The Employee s base salary amount Organizational Unit 1 The department the individual works in Physical/Work Site Where the employee is physically located Reporting Site AAP reporting location Includes all active employees on your payroll as of the snapshot date

15 What Data do I Need? Employees File Typical Issues Encountered Missing Gender/Race information o Best solutions: Re-survey the workforce to obtain this information Have the direct supervisor visually identify (if they are comfortable doing so) Missing Salary information o Use pay grade (if applicable) o Rank order by department Differing Job information o Ensure that job information matches across the files What they applied for is what they were hired on as, what they were promoted to is the current title listed in the employee file, etc.

16 What Data do I Need? Employees File Additional Required Data Fields (if applicable)*: Pay Grade Salary Band Full/Part Time Status Full-Time or Part-Time employee Date in Job Date the employee filled the current job Commission Total additional compensation (in the form of commission) that the employee received Incentives Providing employees with incentives to receive pay increase Bonuses Total additional compensation that the employee received: holiday bonuses, quarterly bonuses, annual bonuses, etc. Merit Increases Performance appraisals Overtime Pay Amount of overtime pay earned during the previous 12-month period Exempt/Non-Exempt Status Employee s FLSA status Hours Worked Number of hours work in a typical workweek for part-time employees *These additional fields are required during an OFCCP Audit

17 What Data do I Need? Applicants File Gender Sex of Applicant (M/F/U) Race Applicant s ethnicity (W, B, H, A, I, 2+, NHOPI, U) Protected Veteran Applicant s veteran status (Y/N/Did Not Provide) Disability Applicant s disability status (Y/N/Did Not Provide) Job Code The unique code of the job title to which the applicant applied Job Title The job title to which the applicant applied Job EEO Category The EEO Category for the job title Reporting Site AAP reporting location Applicant Type Identifying if it was an external or internal candidate Application Date The date the applicant applied Include all applicants associated to the hires made within your transaction period

18 What Data do I Need? Internet Definition of an Applicant Require d Optional Solicit Race/Ethnicity, Gender, Protected Veteran, & IWD 1. Individual Submits Expression of Interest (Electronic) 2. Contractor Considers Individual for a Particular Position 3. Individual Possesses Basic Qualifications 3 Conditions of BQ: Non- Comparative Objective Relevant 4. Individual Does NOT Self- Eliminate Before Offer is Made 5. Individual is an Applicant Individuals who meet all 4 prongs are applicants and will be included in the Personnel Transactions and Adverse Impact Analyses Retain Records

19 What Data do I Need? Hires File Employee Identifier Hire s unique identifier Gender Sex of employee (M/F) Race Employee s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran Employee s veteran status (Y/N) Disability Employee s disability status (Y/N) Job Code The code assigned to each unique job title Job Title The job title the individual was hired into Job EEO Category The EEO Category for the job title Hire Date The date the employee was hired Reporting Site AAP reporting location Includes all new hires or rehires made within the transaction period

20 What Data do I Need? Hires File Typical Issues Encountered How are Seasonal Employees handled? What if someone was hired outside the transaction period, but actually started working within the transaction period? o Is it when the decision to hire was made or when the start date occurred? Missing Gender/Race information

21 What Data do I Need? Promotions File Employee Identifier A unique identifier for promoted employee Gender Sex of employee (M/F) Race Employee s ethnicity (W, B, H, A, I, 2+, NHOPI) Protected Veteran Employee s veteran status (Y/N) Disability Employee s disability status (Y/N) Job Code From The code assigned to the employee s previous job, the one promoted from Job Title From The title of the job from which the employee was promoted from Job EEO Category From The EEO Category for the job title that the employee was promoted from Includes all promotions made within the transaction period. Promotions depend on what your organizations definition of a promotion is

22 What Data do I Need? Promotions File Job Code To The code assigned to the employee s previous job, the one promoted from Job Title To The title of the job from which the employee was promoted from Job EEO Category To The EEO Category for the job title that the employee was promoted from Promotion Type Competitive or Non-competitive (if applicable) Promotion Date The date the employee was promoted Reporting Site From Previous AAP reporting location Reporting Site To Current AAP reporting location

23 What Data do I Need? Promotions File Typical Issues Encountered What if someone was hired internally? o Is it a promotion or is it a hire? o Should transferred be analyzed? Mismatching job information between the Employee and Promotion files What if they were promoted multiple times during the transaction period?

24 What Data do I Need? Terminations File Employee Identifier A unique identifier for each terminated employee Gender Sex of terminated employee (M/F) Race Ethnicity of terminated employee(w, B, H, A, I, 2+, NHOPI) Protected Veteran Terminated employee s veteran status Disability Terminated employee s disability status (Y/N) Termination Code The type of termination (e.g., voluntary, involuntary) Job Code The code assigned to each unique job title Job Title The job title of the employee at the time of termination Job EEO Category The EEO Category for the job title Termination Date Date the employee was terminated Reporting Site AAP reporting location Includes all terminations made within the transaction period

25 What Data do I Need? Terminations File Typical Issues Encountered Should seasonal employees be included? Determining voluntary vs. involuntary terminations Are they still included in the employee file? Includes all terminations made within the transaction period

26 What Data do I Need? Applicants File Hires File Employees File Jane applied for an open position and was hired within the transaction period.

27 What Data do I Need? Applicants File Hires File Terminations File Employees File Jane was terminated within the transaction period.

28 What Data do I Need? Applicants File Hires File Promotions File Employees File: reflect current jobs information Jane was promoted within the transaction period.

29 What goes into Determining my Availability?

30 What goes into Determining my Availability? A central premise underlying affirmative action is that, assuming all else being equal (and absent of discrimination), over time a contractor s workforce will reflect the gender, racial and ethnic profile of those with the requisite skills in the labor areas from which the contractor recruits and selects. If a contractor s workforce doesn t reflect this labor profile, that s when action-oriented programs and outreach & recruitment resources are used to help reach the observed profile. So what goes into determining what we should look like?

31 What goes into Determining my Availability? What we should look like is referred to as the final availability It s an estimate of the number of qualified minorities or women available for employment in a given job group It s a combination of internal and external availabilities (i.e., factors) to identify what those qualified to work in the job group are supposed to look like Once a final availability is calculated, we are able to compare the current composition of the job group to it an determine if underutilization exists

32 What goes into Determining my Availability? External Factor (i.e., typically census data) Step 1: Define the labor areas (local, state, national) Step 2: Assign census occupation codes to all jobs (487 available to choose from) Step 3: Mathematically weight census codes based upon representation within each job group Step 4 (Optional): Identify other relevant data besides the census (e.g., graduate data) Internal Factor (i.e., feeder data) Step 1: Identify feeder jobs/job groups (those employees who are promotable and/or transferable ) Step 2: Mathematically weight feeders based on relevance (e.g., flow/movement of internal employees) IMPORTANT NOTE: Results are only as good as the amount of effort put into this process! But don t get caught in the weeds this is equal parts art and science!

33 What goes into Determining my Availability? Example: Happy Software location in San Mateo Happy Software Corp. HQ (500 Employees)

34 What goes into Determining my Availability? External Factor Step 1: Define the Labor Area(s) Software Developers ( ) Male Female White Black Hispanic Asian NHOPI AIAN 2+ SF MSA 80.0% 20.0% 42.3% 1.3% 3.1% 52.0% 0.1% 0.3% 0.9% Male Female White Black Hispanic Asian NHOPI AIAN 2+ SJ MSA 78.1% 21.9% 30.1% 0.8% 2.3% 65.5% 0.0% 0.2% 1.2% Zip Code or Manual Identification San Mateo: 30% Santa Clara: 30% Alameda: 12% Santa Cruz: 10% San Francisco: 10% Marin: 3% Contra Costa: 3% Stanislaus: 2% What remains is the local labor area (with corresponding weights) Trim spurious and/or misleading labor areas, including those that have negligible contributions

35 What goes into Determining my Availability? External Factor Step 2: Assign Census Occupation Codes Census occupation codes (aka census codes ) are links between your jobs and the external census data Each distinct job is assigned to one (or more) of the 487 codes 2010 Census Code Toolkit The census data for each code is weighted based upon it s representation within each job group.

36 What goes into Determining my Availability? External Factor Step 2: Assign Census Occupation Codes

37 What goes into Determining my Availability? External Factor Step 3: Weight Census Occupation Codes 62.3% of the employees in this job group are in jobs assigned to code 7830

38 What goes into Determining my Availability? External Factor Step 4: Identify relevant data other than that from Census Miscellaneous (potentially) available data sets o Graduate Data o Internal/external training course attendees o Mentorship programs o?

39 What goes into Determining my Availability? Internal Factor Step 1: Identify relevant feeders Internal Factor: o o o Positions are not always filled via external sources it s also necessary to identify internal sources of availability information Step 1: Identify feeders for all job groups Step 2: Weight feeders based on historical promotions data (i.e., datadriven for starters with a heavy dose of personal review because there will be crazy situations. Target Job Group Weight Feeder Job Group 1A Management B Middle Management (Directors) C Managers/Supervisors

40 What goes into Determining my Availability? Internal Factor Step 1: Identify relevant feeders

41 What goes into Determining my Availability? Internal Factor Step 2: Weight feeders 50.0% of the internal movements into job group 7-03 come from job group 7-05 Note: Job groups should never be a feeder for themselves.

42 What goes into Determining my Availability? Final Availability: Assigning Factor Weights Factor Weights: o o The weight given to the internal and external availability data (i.e., factor) for each job group Identifies the relative importance of each set of data Assigning factor weights requires the used to ask the following question: o Out of 100 hypothetical movements into this job group, what number do I expect to come from a local recruitment area, national (or other reasonable) recruitment area, or an internal pool?

43 What goes into Determining my Availability? What We Should Look Like: Final Availability Raw (%) x Factor Weight = Weighted (%) Raw (%) x Factor Weight = Weighted (%) Final Availability (%) = Goal

44 In Conclusion: Summary, Questions and Answers

45 Summary The term employee is broad. If part-time, full-time, and/or temporary employees appear on your payroll as of the snapshot date, they should be covered under an AAP. o Be sure to identify any Corporate Initiative employees. Be careful of data collection pitfalls and do not get hung up on information that you do not need for development. o o Reconciling data is essential for making audit ready Affirmative Action Plans. Only include applicants in which a selection was made during the transaction period.

46 Summary The final product will only be as good as the data that you put in. o o Ensure you have all the required data and you re determining your final availability properly, as this will have a huge impact on the results. Make sure that you assign the appropriate Census Occupation Code for each job title and review your Factor Weights & Feeders annually. Most importantly, if you need help, be sure to reach out and seek the guidance that you require from an HR professional, Consultant, or Legal Counsel.

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