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practices. However, they represent only a small portion of the accompanying statements, narrative and attendant records for the AAP.4

Standard Formats and Model AAPs

We believe that formats for Affirmative Action Plans should be standardized, particularly for small businesses, and that models should be developed by OFCCP for optional use by employers to construct their own plans. Compliance agencies state that volumes of narrative are really not necessary in AAP's. We believe that companies develop voluminous AAP's because they do not understand what the narrative is supposed to reflect. Standardized formats and model plans could help eliminate confusion and unnecessary portions of AAP's.

Recommendation No. 7

OFCCP should develop standard formats for Affirmative
Action Plans, particularly for small employers.

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4 The forms represented by Figures 6 through 9 are included in this report
by authority granted by the Jim Walter Corporation, Tampa, Florida. Further
use or duplication of these forms is not authorized.

Recommendation No. 8

OFCCP should develop optional model Affirmative Action Plans for use by employers, particularly small employers. These model plans could provide examples and illustrations or information requirements, degree of detail in supporting narrative, as well as practical, proven suggestions to help employers reach employment goals.

Companies In Compliance Should Be

Relieved of Some AAP Requirements

A separate, written Affirmative Action Plan is now required annually for each establishment of a Federal contractor or subcontractor which has at least 50 employees and a contract of at least $50,000.

Investigation by the Commission on Federal Paperwork indicated that many AAP's, although prepared annually, are not read or reviewed by compliance agencies that frequently. Additionally, companies that are in compliance year after year must still produce the same type AAP as those businesses which, consistently or periodically, are not at an appropriate level of compliance.

Both public and private critics of AAPS feel that much of the data required in an AAP is not directly related to the level of a company's performance in EEO, such as a one year listing of all job applicants and why they were not chosen.

Several methods have been articulated and proposed to lessen the AAP burden. Some have been criticized because they appeared to weaken the overall EEO program, by decreasing the company's compliance responsibilities, and therefore their performance in equal employment opportunity. During the study, the CFP considered several alternatives.

• For a company that has a history of compliance and a sound internal audit and reporting system, the opportunity to develop a five-year Affirmative. Action Plan could be provided.

• Companies could be allowed and encouraged to develop Corporate Contract Compliance (3C) programs, incorporating an approved Corporatewide Affirmative Action Plan format. Such programs are in place at several corporations, including General Motors, Burlington Industries, Western Electric, and Chrysler.

• When diversified companies must report to more than one compliance agency, there could be a

multiple agency agreement, approved by the Department of Labor, to standardize, to the extent possible, EEO reporting requirements, especially Affirmative Action Plans.

Once a company is certified as being in compliance, the Commission recommends that some relief be given the contractor in the preparation and review of AAP's. Therefore, we recommend that contractors, upon meeting certain criteria, be allowed to develop complete AAP's on a five-year basis with provisions for an annual review and update of information needed by the compliance agency to make periodic determinations.

To qualify for this consideration, a company (establishment) should meet at least the following criteria:

• Certification by a compliance agency as being in compliance;

• Demonstration of good faith efforts;

• Evidence of progress toward goals;

• Indication of good internal controls (audit and report system).

After the first year, the contractor should be required to prepare an update of the availability analysis. If necessary, new annual hiring rates, goals and timetables should be developed.

Recently, the director of contractor employment compliance for the Department of Defense outlined a plan similar to this in a letter to OFCCP. This five-year effort is being conducted experimentally with one large corporation on the basis of an agreement by the company's four compliance agencies-DOD, ERDA, GSA, Interior.

Recommendation No. 9

An Affirmative Action Plan should be required on a fiveyear basis if a company is certified as being in compliance, has demonstrated good faith efforts, shows evidence of progess, and has a good internal audit and report system. Recommendation No. 10

Greater emphasis should be placed on the development of Corporate Contract Compliance (3C) programs, allowing the use of approved corporate-wide Affirmative Action Plan formats.

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