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Newsletter Issue 16

Practical Approaches
to Resolving EEO/AA Problems
Issue #16

It is always great to close out the year with the spirit and joy that comes to us with the celebration of this ancient rite surrounding the birth of Christ. We wish you and your families a most enjoyable holiday season.

With the advent of Christmas we are proceeding to close out the 2006 programs including, for most Government contractors, the affirmative action program. During the few remaining days of this year, it is time to take stock of the results of our affirmative action programs and other EEO issues that play a part in everyday work life. Questions like the following:

Did we meet all of our affirmative action goals? If not, why not?
  • Have position descriptions been reviewed to identify the essential functions of the jobs as revealed through job analysis? Where this has not been done, have corrective actions been taken?

  • Have new jobs been introduced or have some jobs been so modified as to require the development of a new position description? Have steps been taken to do that?

  • Have all employees and especially managers and supervisors received training on EEO subjects, in particular sexual harassment? Remember the courts keep telling us that such training has to be given.

  • Since 2007 will see the introduction of changes in the identification of employee and applicant minority status. Has a survey of the workforce been taken to correctly record each employee’s race/national origin?

  • Have appropriate changes been made in the documents used by applicants to declare the ethnicity? This document should include the additions of the refined identification of minority statuses.

  • Given the OFCCP emphasis on compensation matters, in those instances in which the AAP shows an adverse impact or a standard deviation of 2 or greater, have steps been taken to review the discrepancies to determine if the differences in salaries could stand up in a court of law? If not, this has to be done.

  • Has EEO data been maintained in a manner conducive to the preparation of an AAP?

These are a few of the subjects that need attention. There are many others that could be added. The important factor is that an end of the year audit should be taken so that problems identified and not yet corrected can be prepared for inclusion into the 2007 AAP.

In several previous newsletters we referenced the changes that are to take place when the EEO-1 report is completed. They are repeated here in case the changes have not been retained.

The Revised EEO-1 Report has the following changes:

  • Adding a new category titled “Two or more races, not Hispanic or Latino;

  • Deleting the “Asian and Pacific Islander” category

  • Adding a new category titled “Asians, not Hispanic or Latino”

  • Adding a new category titled “Native Hawaiian or other Pacific Islander, not Hispanic or Latino”

  • Extending the EEO-1 data collection by race and ethnicity, to the State of Hawaii; and

  • Strongly endorsing employee self-identification of race and ethnicity, as opposed to visual identification by employers.

The new EEO-1 Report’s job categories include:

  • Dividing “Officials and Managers” into two levels based on responsibility and influence within the organization:
  • “Executive/Senor Level Officials and Managers”, and

  • “First Level/Mid-level Official and Managers”, and

  • Moving non-managerial business and financial occupations from “Officials and Managers” category to the professional category.

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