Affirmative Action Planning Hurdles
There are three primary hurdles to overcome/work through when preparing an AAP, according to Berkshire:
Understanding OFCCP Requirements,
Gathering the necessary data, and
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.