5 Tips for Working with your Affirmative Action Consultant

So you’ve decided to outsource your Affirmative Action Plan. All you have to do is turn in your data...

Posted by Carolyn Phillips Smith, M.Ed, SHRM-SCP on February 18 2022
Carolyn Phillips Smith, M.Ed, SHRM-SCP

So you’ve decided to outsource your Affirmative Action Plan. All you have to do is turn in your data, right? Not quite… Here are 5 tips for working with your Affirmative Action Consultant to develop your AAP.

  1. Be prepared to answer a lot of questions!

    It’s important for us to know details about your company and what you do, so we can tell your affirmative action story. What services do you provide? Where does your workforce live? How do you source qualified candidates? We may ask about your Applicant Tracking System and how you disposition candidates, or if a termination reason is considered voluntary or involuntary. Our goal is to have the most accurate data in your plan.
    We also want to know how you will use your Affirmative Action Plan, and if you have other Diversity and Inclusion or Compensation initiatives. Who is the internal audience for your plan? Do you need specialized reports or presentation material to show how your Affirmative Action Program is tied to your Diversity and Inclusion or other business strategies?
  2. Don’t be afraid to ask us a lot of questions!

    There are so many reporting requirements and government regulations -- including the new verification requirements; consulting with an expert is a great way to make sure you are staying compliant! Just this year there is a new requirement for Federal Contractors to certify their Affirmative Action Program. Your consultant can provide answers about what the regulations mean and what you should do meet those requirements.
    Often clients have questions about specific events that occurred during the plan year. The COVID-19 pandemic changed how and where we do work. Perhaps you have questions about how your newly “remote” workforce is represented in your data, or what that means for where you source qualified candidates. Similarly, you might have questions on how to prepare for future events—a merger or acquisition, or job family re-structuring. We can advise on how those changes may affect your AAP.
    Finally, you may also have questions about what to do to increase representation, where you can look for qualified candidates, or how to track your outreach efforts. Your consultant can provide resources for these questions and more. Just like they told us in school, there’s no such thing as a dumb question!
  3. Get Ready to Collaborate…

    There will be several points during your plan development where we will need to work together to ensure we are presenting the best and most accurate picture of your Affirmative Action Program. Sometimes we need to come back to you for more information if we notice data inconsistencies. There may also be times where we need to bring in members of your Talent Acquisition Team or Compensation Department to ensure we are capturing the most accurate data. Often, you have choices when it comes to how data is presented, and we should discuss those options with you and your colleagues.
  4. Stick to a Timeline… Flexibly.

    Do you have a deadline for completing your AAP? The answer is yes! Supply and service contractors are required to certify their Affirmative Action Programs in the Contractor’s Portal by June 30, 2022. This is the very first year for that requirement. And, if your consultant is using your AAP data to complete other reporting requirements, we must be aware of those deadlines as well. Maybe you have in internal deadline for your Executive team. Working within a timeline that establishes realistic checkpoints for each part of the process keeps everyone accountable. That said, things happen! We fully recognize that our clients have a lot of work to juggle and sometimes competing priorities. You may just need more time to collaborate internally with your team before making a decision. Stay in contact when this happens; we will help keep the important dates fresh in your mind and offer options for moving forward when possible.
  5. Stay in Contact!

    Remember, if you get an audit scheduling letter from OFCCP, you only have 30 days to submit your compliant Affirmative Action Plan. Make sure your consultant knows as soon as possible to help you make the most of that time!

Even if you aren’t on the scheduling list, do not hesitate to reach out during your plan year! Berkshire can help you plan for next year’s AAP if there are any major changes in your organization. We would also love to hear about new Diversity and Inclusion initiatives and Compensation Projects at your company, so we can share how Berkshire can help support you.

Carolyn Phillips Smith, M.Ed, SHRM-SCP
Carolyn Phillips Smith, M.Ed, SHRM-SCP
Associate HR Consultant

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