Dear Berkshire: How Should I Structure My AAPs for Remote Employees?

The following content was developed as part of our new blog column, “Dear Berkshire.” Instead of trying to anticipate the challenges you're facing at work, we’re going straight to the source. Every several weeks, one of our expert consultants will answer a specific question about compliance, regulatory changes, and affirmative action -- submitted by HR professionals like you!

Q: We currently have multiple sites with individual plans. With the increase in remote employees what is your recommendation on how to choose a plan for them to report into?

A: We recommend utilizing one of the following 3 options:

1. Reporting the employee in the affirmative action program where their supervisor is located.
2. Reporting the employee in the affirmative action program where their hiring selection was made.
3. Reporting the remote employee in the affirmative action program which provides the personnel function support of the employee. 

These options align with the regulations at 41 CFR 60-2.1 and were also provided as guidance from the OFCCP in their FAQs regarding remote and telework employees.  We do not recommend one option over the other, but the method you choose can affect how your AAP-related data is collected and reported, and we recommend choosing the option that will allow you to effectively implement your affirmative action program across your multiple sites.  

Next time you get stuck while working on your affirmative action plan(s) -- or maybe you get a question from a colleague that you’re not sure how to answer – remember that expert advice is just a couple of clicks away! 

Our submission box awaits!