In developing Affirmative Action Plans, one of the key parts of preparing plans is determining the availability settings for contractors. Availability considers a reasonable approximation of both the geographic areas outside the company where candidates are recruited, and making a reasonable list of the positions, groups, or individuals within the company who would be promotable or trainable upwards. From those two factors, a composite availability percentage is established.
Dialing in on the external availability and setting up the geographic areas where candidates are recruited, or the reasonable recruitment area, is extremely intuitive: make a literal map of where candidates are likely to reside. However, how should contractors determine what sub-populations within an area could actually be qualified for the jobs being filled? Let’s take the example of a company determining if they have underutilization of accountants in Washington, DC. It makes sense for this company to narrow the DC metro area workforce, which comprises everyone from accountants, HR professionals to sales executives, college professors, and information security analysts. The census data provides a series of codes mapped to jobs to allow for the specific demographic breakdowns of professions in the area. For the accounting firm, the accounting titles would be matched to code 0800 – Accountants and Auditors to get a specific demographic of only accountants in the DC Metro Area.
Contractors should take great care in being specific in determining both the geographic area and the census match. The census data can break down a region by Accountants and Auditors, but also by Personal Financial Advisors. By being as specific as possible about what is the most representative version of the workforce’s responsibilities, contractors can determine precisely whether a workforce is representative of where candidates who have the skills to do the job are being recruited. During an audit, if OFCCP reviews a contractor’s availability settings and sees what they may believe to be an unrepresentative availability of minorities and/or women in the external availability, they may request to review how the contractor arrived at the composite availability percentages in the plan.