Do You Need an AAP?
An Affirmative Action Plan (AAP) is a tool used to establish guidelines for recruiting, hiring, and promoting women and minorities in order to eliminate the present effects of past employment discrimination. AA organizations must analyze their current employment practices and the makeup of its workforce for any indications that women and minorities are excluded or disadvantaged. The AAP is used as a management tool to help ensure equal employment opportunity (EEO). This is done through diagnostic and quantitative analyses designed to evaluate the composition of your workforce vs. the composition of relevant labor pools.An AAP will set forth measurable employment goals for minorities and women whose representation in the workforce is less than would be reasonably expected based on the availability estimates of the qualified labor pool. Ideally, the percentage of women and minorities working in an organization or in a particular department of an organization should be similar to the percentage of women and minorities available for such positions in the relevant labor market.
Affirmative Action has been upheld by the United States Supreme Court as a permissible method to reach the goal of fair employment. It is NOT a quota system. No individual should be selected solely because of their membership in any group; similarly, no individual should be rejected on that basis either. If and when any problem areas are identified, new goals, policies and practices are developed to solve these problems in effort to eliminate and prevent discrimination.
Government Regulations require that a Federal contractor/subcontractor with 50 or more employees must have and maintain an AAP for each of its establishments that:
1. Has a contract with the Federal Government valued at $50,000 or more; or
2. Has Government bills of lading which in any 12-month period, total or can reasonably be expected to total $50,000 or more; or
3. Serves as a depository of Government funds in any amount; or
4. Is a financial institution which is an issuing and paying agent for U.S. savings bonds and savings notes in any amount.
An AAP is also required for Covered Veterans and Individuals with Disabilities.
If your organization meets the above requirements, you will need a written affirmative action plan (see below for criteria applicable for construction contractors*). AAPs are monitored by the Office of Federal Contract Compliance Programs (OFCCP); an agency within the U.S. Department of Labor. The OFCCP conducts compliance evaluations to determine whether a contractor is complying with its obligation to maintain nondiscriminatory employment practices.
*Contractors and subcontractors which hold any Federal or federally assisted construction contract in excess of $10,000 are also required to complete affirmative action plans.*
