Designing Job Groups for Affirmative Action Plans

A core component of a federal contractor’s affirmative action plan (AAP) is the creation of a job gr...

Posted by Lauren Buerger, SHRM-SCP, HR Consultant on August 11 2022
Lauren Buerger, SHRM-SCP, HR Consultant
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A core component of a federal contractor’s affirmative action plan (AAP) is the creation of a job group structure. The Office of Federal Contract Compliance Program’s (OFCCP) regulations state the “job group analysis is a method of combining job titles within the contractor’s establishment” (41 CFR 60-2.12). However, what does this mean? What is the best way to do this? Why does this matter?

The terms job groups and EEO Categories are sometimes used interchangeably, but often job groups are actually subsets of EEO categories. If you are a contractor with a total workforce of fewer than 150 employees, the regulations state you can create job groups at the EEO category level. However, if you have more than 150 employees, and particularly if an EEO category is over 50 employees, it is recommended to create sub-groupings of job titles within the broad EEO categories.

When do you need to break down the EEO categories into subsets?

Remember, the job groups are the foundation of your AAP—they need to be well built for your AAP to be a useful management tool. Therefore, the size of the job group should result in the ability to set utilization goals and determine whether disparities exist. Consider:

  • Will the size of the groupings enable us to determine whether the percentage of women or minorities in a particular job group is less than would be reasonably expected given their availability?
  • Will we be able to use the job grouping to conduct multiple analyses required by the regulations to determine whether selection or compensation disparities exist?

Not every EEO Category needs to be broken out. For example, if your organization has many Operatives, but few Technicians, you may want to only break out the Operatives into additional groups and keep all Technicians in the EEO category job group.

How should you break the EEO categories down?

If the number of employees in the EEO Category is large enough to warrant sub-dividing, the job group structure needs to be specific to your organization and possibly even the establishment. You want to group similar type jobs based on content (the roles and responsibilities), opportunities (training and career enhancement), and wage rates.

There are no clear rules given by OFCCP, but their Technical Assistance Guide provides some suggested approaches:

Approach 1: Content/Function Driven

Under this approach, jobs are grouped together based on similar content or function (i.e.: Administrative Professionals, Technical Professionals, Finance Professionals, Engineers). This approach usually means there are easier to define recruitment areas for the job groups.

Approach 2: Opportunity/Level Driven 

Under this approach, jobs are grouped together by level, wage rate, or opportunity (i.e.: Senior Level Professionals, Entry Level Professionals). This approach is best to reflect promotional movement in goal attainment.

Still not sure where to start? Here are 3 Tips!

Tip 1: Think about your pay structure.

Do you have pay ranges already established? Are those pay ranges based on function or level? The OFCCP’s Technical Assistance Guide states that “large apparent differences in pay within a job group can suggest an unacceptable job grouping”. If your pay structure is based on level, but your jobs are grouped by content, does it really make sense to analyze Senior Technicians with Apprentices? Similarly, if your job groups are based on opportunity/level, but your pay structure is based on functions, does it really make sense to analyze entry-level commission-based sales representatives with entry-level non-commission-based sales representatives?

Tip 2: Think about if there are any jobs that have special criteria for any type of selection decisions.

For example, we recommend putting Union Craft Workers in a separate group from Non-Union Craft Workers since recruitment, pay, career opportunities, or other selection decisions are often made very differently. Similarly, specific jobs that require certain criteria, for example, having a security clearance or CDL license, might make sense to be in a separate group. This will allow you to more accurately determine the availability of minorities and women with those criteria. This allows for analysis of underutilization and better comparison of compensation, since those requirements often determine different pay rates.

Tip 3: It’s OK to be inconsistent.

Just like how not every EEO Category needs to be broken out, you also don’t have to use the same approach for each group. For example, it might make sense for you to break out Technicians into groups based on opportunity/level but break out Sales into groups based on content/function. You can also combine approaches. If your organization employs mostly professionals, it might make sense to break out job groups by content/function AND opportunity/level (i.e., Senior Technical Professionals, Senior Engineers, Senior Administrative Professionals, Entry-Level Technical Professionals, Entry-Level Engineers, Entry-Level Administrative Professionals).

Whichever approach you choose, it is important to be able to explain how you created job groups if asked during a compliance evaluation. Your job group structure should be evaluated regularly, especially when there are significant changes in your organization. Although job group structure can be revised at any time, many contractors strive to keep their job group structure relatively consistent from one AAP year to the next for accurate goal attainment and adverse impact analysis. You also want to think about what affect any changes might have on other systems. Do you use the same structure in your HRIS system? While the AAP job groups don’t have to be the same as other internal groupings your company might use, you will want to consider if there are other reports outside of the AAP that use job groups to communicate diversity or other results to the field. You also may need to consult with your compensation team or other teams to ensure consistency.

While there are few strict guidelines on how to design your job groups, since most of the AAP analysis are done by job group, it is critical that contractors think about their job group structure carefully. Why does all this matter? Analyzing the roster by job group allows contractors and OFCCP to locate with more accuracy where a need for a placement goal might exist. Job groups are the unit of analysis for most of the reports in the AAP, including a contractor’s personnel activity such as hiring, promotions, and terminations, so it is important they are correct. Once the EEO Category is broken down, you might discover you have a placement goal for minority scientists, or senior level engineers, even though the total number of minority and female professionals in your organization is higher in other professional job titles.

Looking for more information on job groups? Sign up for our webinar to learn how to master this crucial part of your AAP.


Lauren Buerger, SHRM-SCP, HR Consultant
Lauren Buerger, SHRM-SCP, HR Consultant
Lauren Buerger is an HR Consultant with over five years of experience at Berkshire. She specializes in helping federal contractors comply with affirmative action regulations and developing AAPs and educating clients.

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