Planning For Your New AAP Year

If you are one of the many federal contractors who have a January 1 plan date, now is the time to start thinking about what actions you will need to take to begin to prepare your new affirmative action plan(s). Your January 1 plans expire at the end of the year, so it is imperative that you be ready to hit the ground running come January 1st of the new year to begin your AAP development. Preparing in December for the new year helps you to make your AAP development process more efficient.

Considerations for your new AAP year:

1. Consider implementing a deadline to have all 2023 transactions processed in your HRIS, especially if you know that some activities tend to be processed retroactively. By implementing a deadline, you will know when you can pull your data reports and feel confident that you have captured all the necessary activity that occurred during the prior 12 months.
   
   
2. Did your company implement a new HRIS or Applicant Tracking System during the last year? If so, you will need to have new reports developed to pull the data needed for your AAP. You may need to provide your report requirements to another team to build them. Don't forget to leave time to test and validate your new reports to ensure you have the data required and that it is an accurate representation of all the activity that you are required to analyze as part of your AAP.
   
   • You will need a report that can pull a snapshot of each employee as of January 1st, 2024, that includes details like their name, job code or title, race/ethnicity, gender, department, salary or hourly rate, and more depending on how much information you have available. You will want to make sure that your report is pulling this information "as of" your plan date, no matter what date you run your report. And if you are unable to pull anything but current information from your system, you want to make sure the current data report is ready so that you can run it on January 1st.
   • In addition, you will need reports or a single report that provides you with all hire, termination, and promotion activity from January - December 2023. Ideally you will want a separate report for each type of activity, although a single report with all activity may be easier for you or your data reporting team to develop. For each activity, you will need to know the employee number, their race/ethnicity and gender, the job code/job title, and the date (hire date, promotion date, or termination date) of the activity.
   o For promotions, it's helpful for your report to show both the job code/title prior to the promotion, and the job code/job title after the promotion. And do you track different types of promotions, like step progression, management discretion, or competitive promotions? The type of promotion can also be useful information.
   o For terminations, you will also need to include the termination reason so that you can determine whether that termination was voluntary or involuntary.
   • Finally, you will need an applicant report from your ATS that will show all applicants for each job filled during the prior year. Your new report should show each applicant name, race/ethnicity and gender, job applied for, how far each job seeker made it through the process, and their final status.
   • If you switched systems, another consideration is when you converted to your new HRIS or ATS. Often, a move to a new HRIS or ATS means pulling data from both the old and the new systems for a period of time. Make sure you still have access to your old systems or at least the data from your old systems. You may also need to think about if and how you will join the data from these separate systems together.
3. Once you have your data reports, it’s wise to check your employee counts to see if you need to establish any new AAP locations that did not exist the prior year.  Assuming you do not expect any significant changes to occur in December, you can pull a preliminary roster and check these numbers before January 1. 
   
   • A small establishment that was previously under 50 employees and rolled into a larger establishment for AAP purposes may now be over 50 employees and need a separate AAP. 
   • Or, you may have lost employees at a location that is now below the 50-employee threshold. You will need to decide if you continue to maintain a separate AAP for these locations or if you will now roll them into a larger location. You might take into consideration how far under 50 employees it is and whether you anticipate adding employees to the location in the next year. 
   • If a location hovers around 50 employees ± a few people from year to year, it can be beneficial to keep a separate AAP for the location to maintain consistency.
4. If you do have new AAP locations, or even if you don’t, give some thought to how your reasonable recruitment may have changed over the last few years. Where and how people are working is still in a state of flux since the COVID-19 pandemic. Are you now recruiting and hiring from a broader area if some, or all of your workforce has the option to work remotely? This change in recruitment strategy opens your applicant base and may also change your availability statistics, which are used to establish goal areas. Talk to your recruitment team to find out if their recruitment strategy is now different than what your AAP shows.
5. If your company implemented any new job codes over the past year, those new jobs must be assigned to the correct EEO-1 category and a job group. Whether you have added just a few new job codes or fully overhauled your system and implemented entirely new codes, you should be thinking about where those codes will fit into your AAP. And if your workforce has changed significantly in the past year, with new locations, more or less employees, and/or different types of jobs, you might want to start thinking about your job group structure and whether your old job groups still make sense for your organization as it is now. Some advance consideration of your changing workforce should make a more efficient process of developing a new job group structure in the new year.
6. Have you been tracking all your outreach/good faith efforts throughout the year?  Now is the time to wrap up your tracking efforts or start to gather them if necessary. 
   
   o Best practice is to track these activities in a central place, such as Berkshire’s balanceREACH tool or even a simple spreadsheet. 
   o Reach out to your recruitment team, HR business partners, or others who play a role in outreach for the organization to ensure all efforts are captured.
   o Don't forget that you need to evaluate or assess the effectiveness of your efforts. Effective assessments will include information such as how many people you spoke to or how many qualified candidates applied as a result and how many hires were realized. If some of your efforts were less than successful, now is also a great time to think about what you could do differently.

Even as your AAP year is coming to an end, the work of an affirmative action plan is ongoing. Using the time at the end of your AAP year to begin preparatory work for your new plan year will help you to develop your new AAPs in a thoughtful and efficient manner.

Join us on January 17 for a free “Ask Me Anything” webinar. This webinar will give you direct access to one of our expert consultants, who will reserve up to an hour of time to field questions from webinar attendees regarding affirmative action plan preparation in 2024.

This webinar will be LIVE only – no recordings will be provided out of respect for the privacy of attendees – so be sure to save your spot now!