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Recommendation No. 5

OFCCP should standardize Information required for compliance reviews. These information requirements should be given to Federal contractors, at their request, to facilitate recordkeeping and to simplify the review pro


Duplication in the EEO-1

In addition, we call attention to Item No. 10 of the compliance letter requiring that the company develop two EEO-1 forms showing current employment and employment twelve months previously.

The EEO-1 is normally filed annually on March 1 with EEOC. If a compliance review is performed, for example, in July, it means that the company must develop a new EEO-1 filed in March.

The new EEO-1's are used for comparison purposes with the other information required for the compliance review. We believe this is an unreasonable demand for duplicative information and that it should be eliminated.

Recommendation No. 6

EEO compliance agencies should not require companies to complete additional EEO-1's for the purpose of contract reviews. The file copy of the data filed on March 1 should be used.

Affirmative Action Plans (AAP)

Affirmative action plans are by far the most troublesome requirement for employers. The difficulty arises from a lack of specificity or standardization of AAP requirements on the part of Federal compliance agencies.

There are four basic components of an AAP:

• The workforce analysis is a profile of the workforce with details indicating rank, breakdown by sex and minority group. Each job title must have grade or salary range attached. The purpose of this analysis is to identify underutilization of the affected classes which are entitled by law to a remedy.

•Utilization analysis requires that contractors regroup job titles on the basis of major job groupings. A comparison of these figures are made with the availability of the affected classes in the area from which the labor force is drawn. The source of the labor market area is the Department of Labor.


Goals and timetables are required when there is a
discrepancy between the number in the affected
classes who are employed and the number
available in the labor market. Goals and timetables
must be set which provide for the eradication of the

• In the narrative portion of the plan a contractor
must show proof of the development or reaffirma-
tion of its equal opportunity policy and must
disseminate that policy both internally and exter-

The AAP is not technically classified as a form, and is
therefore not cleared by OMB. It is, however, the most
controversial of all of the Federal Government's EEO
reporting requirements. Some firms acknowledge the
value of going through the AAP exercise, indicating that
the process forces them to:

• review their progress (or lack thereof) in EEO over
a period of time;

look at their present posture;

• set goals for future improvements in the hiring and
upgrading of people in the affected classes.

On the other hand, most respondents who express an
opinion are highly critical of the Government's administra-
tion of this reporting requirement. The most common
criticisms are:

• The AAP is too lengthy and requires information
that does not appear to be helpful in achieving EEO

• Many AAPs are put together with a significant time
and financial investment but are never reviewed by
a compliance officer.

• There is little uniformity in what is an acceptable
AAP between different compliance agencies, and
in some cases, within the same agency. The
present guidelines allow great latitude in interpre-
tation, causing different compliance officers to
have varying standards of judging an AAP as
acceptable or unacceptable. This situation, con-
fusing at best, is a disservice to the Government as
well as to contractors and grantees.

Figures 6 through 9 illustrate the types of statistical data
prepared by corporations for Affirmative Action Plans.
The included tables contain pertinent data on hiring


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