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Executive Order 11246 requires all contractors
and subcontractors with a federal contract of
$50,000 or more, and 50 or more employees, to
develop a written affirmative action plan.
The Office of Federal Contract
Compliance Programs ("OFCCP")
enforces the affirmative action plan requirement,
and monitors government contractor and
subcontractor compliance with nondiscrimination
laws.
Preparing an affirmative action
plan involves an in-depth analysis of the total
employment process to identify any impediments to
equal employment opportunity.
At a minimum, the employer must
evaluate its workforce by organizational unit and
job group to determine whether there are problems
with the utilization or distribution of women and
minority employees.
Each affirmative action plan must include the
following:
- Work force analysis.
List of job titles by department, with number of
employees by gender and
race, along with salary range for each job
group.
- Job group analysis. List of
jobs with similar content, wage rates, and
opportunities, combined to form job groups.
- Utilization analysis.
Percentage of minorities and women in each job
group.
- Availability analysis.
Availability of women and minorities in the
relevant workforce.
- Reasonable recruitment area.
For each job group, with a brief explanation of
the rationale for selecting that area.
- Placement goals. When the
percentage of minorities and women employed in a
particular job group is less than would
reasonably be expected given their availability,
the employer must establish a placement goal.
The attorneys of Harris Dowell Fisher & Harris, L.C. provide services in connection with
affirmative action plans, including preparing
and reviewing such plans and responding to OFCCP
compliance activities.
Contact us to discuss how
we may best assist you in this regard. Related
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