The Top 3 Struggles Contractors Face in Affirmative Action Planning

Whether you’re a new federal contractor or have been completing Affirmative Action Plans (AAPs) for ...

Posted by Berkshire on November 29 2023

Whether you’re a new federal contractor or have been completing Affirmative Action Plans (AAPs) for years, affirmative action compliance can be tricky. To keep your organization compliant with Office of Federal Contract Compliance Programs’ (OFCCP) regulations, you’re going to need to arm yourself with the necessary information and resources. In doing so, things can get stressful. Some days you may wonder if it’s all worth it, but I promise you, it is!

The three most treacherous obstacles federal contractors face when it comes to AAP’s are:

  1. Understanding OFCCP Requirements
  2. Gathering Data
  3. Implementing the AAP Across the Organization

OFCCP Requirements

To succeed, you will need to understand OFCCP requirements. OFCCP’s website gives you a ton of useful guidance. However, some of the information can be confusing—especially if this is your first foray into creating an AAP. It is recommended you attend a class that covers:

  • Creating a written AAP
  • Calculating availability
  • Setting goals
  • Understanding OFCCP’s definition of an applicant
  • Analyzing personnel actions
  • Writing narrative reports
  • Preparing for the OFCCP audit process
  • Implementing the AAP

Training that includes these topics, at a minimum, should give you a solid understanding of the AAP process.

Note: In addition to attending training, consider whether you have the time to invest in completing your company’s AAP(s). If your time is already limited, it’s acceptable to partner with a reputable company who can complete your AAP(s) using your data.


This brings me to the second biggest struggle: gathering data. To complete an AAP, you’ll need access to your employee roster, personnel actions, and applicant data. The roster and personnel actions are usually the easiest to gather. Easiest, if your records accurately reflect job titles (classified using proper EEO categories), grades, department codes, termination codes, promotion codes, race/ethnicity, gender, etc. You’ll also need records of hires, re-hires, promotions, transfers, and terminations.

Applicant data, on the other hand, may leave you wondering if left is right! If you do not have an efficient applicant tracking process (software or system), you may find it close to impossible to organize all the applicant information. Further, if your applicant flow process is not set up to solicit the required information from applicants, you could end up with stacks of information that have very little use in the AAP process.

If you find gaps in your information, I recommend you familiarize your team (including any third-party recruitment firms), with the Uniform Guidelines on Employee Selection Procedures (used by OFCCP to define “traditional” applicant), the OFCCP’s definition of an Internet Applicant, and effective disposition codes. Implement a process to solicit race/ethnicity, gender, Veteran, and Individual with Disability statuses from applicants. The easiest way to solicit and store this information would be to invest in a web-based applicant tracking system to automate your process.


Let’s say you live in a perfect world where your AAP knowledge is solid. You have all of your personnel actions in an efficient HRIS system. Your applicant tracking system collects data and organizes it with your AAP in mind. You also have plenty of time to complete the AAP. Your mathematical calculations are perfect. Your narratives are the stuff of legends. Now what? How do you implement your AAP across your organization?

If you have completed the narrative section of your written AAP, you should have already developed a goal attainment plan with clearly defined and measurable action items. Include your AAP goals in your human resources strategic objectives and corporate goals. Evaluate these programs regularly. With goals established, it’s best to make sure your staff understands the AAP and their roles in compliance. This is another place where training can be used to bring everyone up to speed. Training is especially helpful for managers and executives, as they have huge roles in managing personnel actions, supporting good faith efforts, and dealing with noncompliance.

Affirmative action planning can be tricky, no matter your experience. By recognizing and overcoming these three major pain points, you are well on your way to completing your AAP with ease!

For information on AAP support, including trainingsoftware, and consulting services, please contact Berkshire at 800.882.8904.

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