Preparing an Affirmative Action Plan

PresentersDebi Freund

Leah Glende

Eric Smith

Amanda Anduaga-Roberson

Nick D’Agostino

Sharon Gaddy

Preparing an Affirmative Action Plan

What You Need, When You Need It, Where to Get It

INTRODUCTION:

• The following are some general guidelines, definitions and hints on completing the Affirmative Action Plan for submission to Commission on Human Rights and Opportunities (CHRO)

• This information and training is not a replacement for CHRO regulations and has not been approved by CHRO

• Please consult CHRO regulations for specific requirements and further clarification of details

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Preparing an Affirmative Action Plan

• In general, previous AA Plan submissions approved by CHRO are the best place to start.

• A good source of guidance is CHRO itself. CHRO can answer questions and offer technical assistance

• You must address any CHRO recommendations, suggestions or requests made in CHRO critiques of your AAP

• The regulations require the Agency to address and/or improve weaknesses and/or deficiencies identified in prior submissions

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POLICY STATEMENT (Sec. 46a-68-33)

The Policy Statement document should state clearly the Agency’s commitment to Affirmative Action (AA) & Equal Employment

Opportunity (EEO)

MUST INCLUDE:

•Consult CHRO regulations for specific items that MUST be included in your policy statement found on the CHRO website AA PLAN REGULATIONS

•Must be updated for relevant changes in the law

•Should be dated after the close of the plan period and signed by the Appointing Authority.

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This section outlines internal communications related to AA/EEO communications

MUST INCLUDE:• Narrative summarizing activity during reporting period• Annual distribution and/or posting of AA Policy & Summary of

Objectives to all Agency staff

• Invitation to staff to review and comment on the AAP with specific time period and contact information of how to do so

• Agency provision of a minimum of three hours of Diversity training and compliance reporting for new employees

• See CHRO regulations

INTERNAL COMMUNICATION (Sec. 46a-68-34)

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This section includes information, memos, notices and explanations of programs concerning Affirmative Action/Equal Employment Office

(AA/EE) communication and contacts with the community OUTSIDE the Agency.

MAY INCLUDE:• Agency Contacts/Recruitment Log

MUST INCLUDE: • Narrative summarizing activity during reporting period• Written expression of commitment to AA/EEO (e.g. employment

advertising sample)• Union letters stating the Agency is an AA/EEO employer and invitation to

review AA Plan• Supplier Diversity (Small Business & Minority Set Aside)• See CHRO regulations for other items that MUST be included

EXTERNAL COMMUNICATION (Sec. 46a-68-35)

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This section includes statements identifying and defining individuals who are responsible for Affirmative Action/Equal

Employment Opportunity (AA/EEO) in the Agency.

•MUST INCLUDE:

• Narrative summarizing activity during reporting period

• Commissioner’s emphasis of human/intergroup relations, nondiscriminatory employment practices, legal authority of AA/EEO and commitment thereto, review of the AA Plan goals and objectives

• Evaluation of staff, Managers/Supervisors’ regarding performance of AA/EEO responsibilities

• List percentage of time of staff with AA responsibilities

• Membership lists of Employee Advisory Committee and minutes of monthly committee meetings by regulation

ASSIGNMENT OF RESPONSIBILITY (Sec. 46a-68-36)

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This section defines the structure of the workforce and how each job title fits into that structure. The job titles and groups defined in this section are those that will be further defined and analyzed

in the remainder of the Plan.

MUST INCLUDE:

•Agency Organizational Chart

•JOB TITLE STUDY - Arrange each office, position and classification into lines of progression that shows the order of jobs through which and employee may advance. Titles without promotional opportunities are listed separately Job Title Study

•OCCUPATIONAL CATEGORY STUDY – Arrange each office, position, and classification in an occupational category with others having similar job content, compensation and opportunity. Titles are ranked from highest to lowest with salary ranges noted Occupational Category Study

ORGANIZATIONAL ANALYSIS (Sec. 46a-68-37)

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EEO CATEGORIES

1. Official/Administrators – Statewide

2. Professionals – Statewide

3. Technicians – LMA

4. Protective Services – LMA

5. Paraprofessionals – LMA

6. Office/Clericals – LMA

7. Skilled Craft – LMA

8. Service/Maintenance - LMA

WORKFORCE ANALYSIS (Sec. 46a-68-38)

Each employee in the workforce is counted according to his/her race, sex, age and disability. This information is recorded in several different ways. Full time and part time employees are

recorded separately.

1. Total agency workforce by occupational category2. Total agency workforce by office(s), position(s), and position

classification(s) within each occupational category3. Agency workforce in each LMA by occupational category4. Agency workforce in each labor market area by office(s), position(s),

and position classification(s) within each occupational category5. In 5 year increments, the age groupings of the full-time workforce by

occupational category6. The number of physically disabled persons in the full-time workforce

by occupational category

• DCF Workforce 10

Data you MUST have for each employee for these analyses:

• Name

• Status (full or part-time employee-FTE)

• Sex

• Race (Ethnic Group in CORE CT)

• Date of Birth (Birth date in CORE CT)

• Job Title

• Occupational Category (EEO Cat in CORE CT)

• Labor Market (County in CORE CT)

• Type of Employee (Class in CORE CT ~ Permanent, Temporary, Durational)

WORKFORCE ANALYSIS CONTINUED (Sec. 46a-68-38)

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This section is an analysis of the individuals who are available for employment within your agency. Employment, unemployment, and internal candidate pools are used to determine the availability base

Statistics used for the Availability Analysis are line referenced from the following sources:

•The CT Occupational Statistics data will remain constant until new Census data is released. Changes in line references should be necessary only if job classifications/groups are redefined, or if changes are suggested by CHRO Volume 1 Western 2000 Census Employment

AVAILABILITY ANALYSIS (Sec. 46a-68-39)

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• The Connecticut Labor Force Data for Affirmative Action Plans provides quarterly unemployment labor force information for Connecticut and its nine labor market areas DOL Unemployment Data

• List of employees eligible for promotion and/or transfer for each separate analysis

Additional data relevant to your agency may be utilized upon agreement with CHRO

AVAILABILITY ANALYSIS CONTINUED (Sec. 46a-68-39)

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This section uses data compiled in the Workforce and Availability Analyses to evaluate the race/sex breakdown to determine parity

and establish goals for the coming year.

You Will Need:• Full Time Workforce Analysis data• Final Availability Factors • The Utilization data from the previous year• Projected Turnovers, Hires and Promotions• Hire/Promotion/Upward Mobility goals from previous year• This reporting period’s hires and promotions

UTILIZATION ANALYSIS (Sec. 46a-68-40) & HIRING/ PROMOTIONAL GOALS &

TIMETABLES (Sec. 46a-68-41)

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The employment analyses consists of four (4) separate analyses which report on the Full Time workforce.

1. Employment Process Analysis: all changes, increases and decreases to workforce during reporting period

2. Applicant Flow Analysis: applicant/interview process

3. Personnel Evaluation Program: service ratings and discipline

4. Training Program: statistical reporting of training

EMPLOYMENT ANALYSES (Sec. 46a-68-42)

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1. EMPLOYMENT PROCESS ANALYSIS:

The Employment Process Analysis reports changes in your agency workforce by race/sex. This includes all hires, promotions, transfers, terminations, etc.

MUST INCLUDE:

1. Prior workforce numbers

2. Current workforce numbers

3. Increases (hires, transfers, promotions, etc.) during reporting period

4. Decreases (resignations, terminations, etc.) during reporting period

5. Any other changes

EACH PAGE MUST BALANCE

EMPLOYMENT ANALYSES CONTINUED (Sec. 46a-68-42)

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2. APPLICANT FLOW ANALYSIS:

The Applicant Flow Analysis examines the application and interviewing process by race/sex

MUST INCLUDE:

1. Race/ sex data on all individuals applying from within agency, other state agencies, outside candidates, reemployment, etc.

2. Race/sex data on qualified and rejected individual applicants

3. Race/sex data on all persons on state examination

4. Race/Sex data on Interviewed, Offered Position and Refused Position

5. Race/ sex data on Accessions (Employment Proc. Analysis)

EMPLOYMENT ANALYSES CONTINUED (Sec. 46a-68-42)

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3. PERSONNEL EVALUATION ANALYSIS:The Personnel Evaluation Analysis reports on all performance appraisals and disciplinary actions, that occurred during reporting period by race/sex

– Form may be adjusted, as needed, for collective bargaining purposes

4. TRAINNG ANALYSIS:The Training Analysis reports on the participation of employees in all training programs occurring during reporting period by race/sex

EMPLOYMENT ANALYSES CONTINUED (Sec. 46a-68-42):

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This section identifies systemic change imbalances in the application and employment processes. The results of these tests are then used to determine agency Program Goals and Timetables

• 1-13 are non-quantifiable barriers to equal employment

• Adverse impact tests 1-6. Only necessary for classifications that have experienced a change in workforce

• CHRO regulations define these tests as designed to: "examine personnel policies and practices to identify those non-quantifiable aspects of the employment process which may impede or prevent the full and fair participation of protected Race/Sex group members in the employment process."

IDENTIFICATION OF PROBLEM AREAS (Sec. 46a-68-43):

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Adverse Impact Tests

Adverse Impact (AI) tests are designed to analyze the participation of each Race/Sex group in the following ways:

1. The Qualified Applicant Pool vs. the Availability of the group as determined in the Availability Analysis

2. The Passing Rate on State Examinations vs. the Rate of Individuals Taking the Exams

3. The Interview Rate vs. those Eligible (Eligible refers to those passing the State Exam for the Position)

4. The Hiring Rate vs. the Interview Rate

5. The Hiring Rate vs. the Applicant Pool

6. The Reduction Rate of the Workforce

IDENTIFICATION OF PROBLEM AREAS CONTINUED (Sec. 46a-68-43)

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To complete the Adverse Impact Tests you will need:

IDENTIFICATION OF PROBLEM AREAS CONTINUED (Sec. 46a-68-43):

DATA SOURCE

Final Availability Factors Availability Analysis

# Qualified Applicants Applicant Flow Analysis Line I

# Taking Exam Applicant Flow Analysis Line J

# Passing Exam Applicant Flow Analysis Line K

# Interviewed Applicant Flow Analysis Line O

# Hires Applicant Flow Analysis Line S

# Applied Applicant Flow Analysis Line G

# Reduced Employment Process Analysis Line Q

PRIOR filing’ s Workforce Numbers Employment Process Analysis Line B

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Establish program goals and timetables to remedy problems identified in Identification of Problem Areas.

MUST INCLUDE:• The statistical results of each Adverse Impact (AI) tests for each job group

• A summary analysis of the six AI tests, outlining each Race/Sex group adversely impacted

• Where adverse Impact is identified, a program goal must be established in every instance that is statistically significant

• Program goals established to address problems identified in the previous element

• A timetable not exceeding one year for remedy of problem area

• Identify person responsible for each goal

• Additional goals may be established per agency need

PROGRAM GOALS AND TIMETABLES (Sec. 46a-68-44)

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Outlines the agency’s career entry & career mobility programs.

MUST INCLUDE:• Narrative concerning present program and plans for the future

(Sections 1-14 of this element)

• Analysis of the Upward Mobility goals set in the previous AAP

• Establish specific goals and timetables

• Upward Mobility Contacts and Resources

UPWARD MOBILITY (Sec. 46a-68-45)

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The agency shall establish a system to provide for the expeditious resolution of allegations of discrimination

MUST INCLUDE:

• Timeline for handling of grievances (90 days)

• Copy of internal discrimination grievance procedure based on regulations

• Summary of complaints by enforcement agency, protected class and outcome during the reporting period

GRIEVANCE PROCEDURE (Sec. 46a-68-46)

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Outlines the Agency’s internal evaluation procedure to monitor progress and anticipate shortcomings in the Affirmative Action

Program

MUST INCLUDE:

• Written narrative of activity during reporting period

• Written input from Appointing Authority

• Written input from designated Affirmative Action Officer

• Written input from Employee Advisory Committee (EAC)

• Relevant memos and narratives

INTERNAL PROGRAM EVALUATION (Sec. 46a-68-47)

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• Each agency shall prepare a narrative report on all activity undertaken to achieve the hiring, promotion, upward mobility and program goals contained in the previous affirmative action plan and a critical self-analysis of the progress made toward those ends.

• Each goal shall be separately addressed and the discussion of action taken in furtherance thereof shall be detailed, searching and complete. If the analysis reveals additional problem areas or finds any current course of action ineffective, the agency shall undertake corrective action.

GOALS ANALYSIS (Sec. 46a-68-48)

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Details the development and implementation of programs not covered elsewhere in the plan. Each agency is urged to structure innovative, comprehensive programs to create

opportunities not otherwise available to achieve the full and fair participation of all protected group members.

MUST INCLUDE:

• Refer to CHRO regulations for specific inclusions (Numbers 1-11)

INNOVATIVE PROGRAMS (Sec. 46a-68-49)

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• States that the Appointing Authority has read the submission and that the contents are true and correct to the best of his/her knowledge

• Pledges the appointing authority’s and agency’s good faith effort to achieve the objectives, goals and timetables established in the plan.

MUST be signed and dated by the Appointing Authority

CONCLUDING STATEMENT (Sec. 46a-68-50)

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STANDARD OF REVIEW (SEC. 46a-68-59)

a. Must contain all 18 elements

b. A Plan shall be approved only if:

1. The workforce considered as a whole and by occupational category, is in parity with the relevant area; OR

2. The agency has met all, or substantially all, of its hiring, promotion, AND program goals; OR

3. The agency has demonstrated every good faith effort to achieve such goals and despite these efforts has been unable to do so; AND

4. The agency has substantially addressed deficiencies noted by the commission in prior plan review

Conclusion

• Any Questions?

Show WORKFORCE ANALYSIS here

AFFIRMATIVE ACTION PLAN DOCUMENTS

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EMPLOYMENT PROCESS ANALYSIS INSTRUCTIONAL DOCUMENT

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Show AVAILABILITY DATA used here

AFFIRMATIVE ACTION PLAN DOCUMENTS

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Show PROMO for AVAIL DATA used here

AFFIRMATIVE ACTION PLAN DOCUMENTS

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UTILIZATION INSTRUCTIONAL DOCUMENT

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APPLICANT FLOW INSTRUCTIONAL DOCUMENT

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CERT LIST DEMO

CERT LIST DEMOGRAPHICS

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ADVERSE IMPACT INSTRUCTIONAL DOCUMENT

Show ADVERSE IMPACT here

ADVERSE IMPACT INSTRUCTIONAL DOCUMENT

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SAMPLE DAS JOB SPECIFICATION

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APPLICANT FLOW & GOALS ANALYSIS

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