Preparing for January 2022 Affirmative Action Plans

If you are like many federal contractors who have a January 1 plan date, you're probably thinking ab...

Posted by Heather Gale on December 6 2021
Heather Gale
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If you are like many federal contractors who have a January 1 plan date, you're probably thinking about what actions you will need to take in a few weeks to begin to prepare your new affirmative action plan(s). Actually, you should be thinking about what you can and should do now to prepare for your new plan year and make your AAP development process more efficient.

For example, 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, 2022 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 actually 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 2021. 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, their race/ethnicity and gender, the job code/job title, and the date (hire date, promotion date, or termination date) of the activity.
    • 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.
    • 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.

If your company implemented 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.

OFCCP is requiring all AAPs with a plan date of January 1, 2022 or later to utilize the new 2014-2018 EEO Tabulation. If you are a Berkshire client, your Berkshire Consultant will help with transitioning to the new codes. If you develop your AAPs in-house, you will need to select a new census code for each of your job codes. Visit the Census Site to view the 2014-2018 EEO Tabulation and find a crosswalk translating the 2006-2010 occupations to the new 2014-2018 occupation codes.

Don’t forget about the documentation of your outreach/good faith efforts. Do you track your activities in a tracking system like Berkshire’s REACH or a spreadsheet? Have all your activities been entered into your tracking tool? If not, now is a good time to get this information up to date with your activities. Or perhaps you haven't been tracking your efforts in a central repository at all. Use this time at the end of your plan year to gather this information together in a central place. You may need to reach out to your recruitment team, HR business partners, or others who play a role in outreach for the organization. While you are pulling this information together, 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 though your AAP year is coming to an end, the work of an affirmative action plan is ongoing. Use this time at the end of your AAP year to begin preparatory work for your new plan year that will help you to develop your new AAPs in a thoughtful and efficient manner.

One final note, the OFCCP recently announced that all federal contractors will be asked to certify that they have an up-to-date Affirmative Action plan by June 30, 2022, so the timeliness of getting your data together is now more important than ever.

Heather Gale
Heather Gale
With 15 years of experience in affirmative action compliance and EEO, Heather is adept in developing compliant recruitment processes, analyzing personnel processes, training human resources staff and management on AA requirements, and supporting organizations in OFCCP audit and complaint activity.

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