According to a new notice on the OFCCP’s website, the 2021 AAP cycle will be the last for which the agency will accept external availability estimates based on 2006-2010 5-Year ACS data. For AAPs prepared on or after January 1, 2022, the OFCCP will expect contractors to be using the new, 2014-2018 EEO Tabulation. Contractors preparing AAPs that will begin before that date have the option of using the “new” data or sticking with the “old” for one more trip around the merry-go-round.
Contractors, vendors, and employers have been struggling to update systems with the new data since it was quietly released back in March. Contractors and vendors will download entire Census databases in order to service a wide range of clients. Employers, however, tend to rely on publicly available search tools to extract just the data they need. This service was previously available through americanfactfinder.com, but that site was shut down while public access to the data was being moved to the Census Bureau site. That search functionality is (finally) now available.
Contractor employers will likely need to re-map at least some job codes due to changes made by the Census Bureau. All contractors are encouraged to at least double-check that Census job code assignments are still “correct.” Census job codes and “crosswalks,” documents that help you map your organization’s jobs to these codes, are available on the Census website. If you use a consultant or vendor for this, check their work—they do not have the institutional knowledge that is available to you, so their Census job code assignments should always be viewed as “preliminary” or “draft.”
Does this mean that the “old” Census data can be tossed in the bin and forgotten? Not necessarily. Changes in the availability figures themselves can be useful for identifying potential problem areas, developing resulting action-oriented programs, and even testing the reliability of the Census data itself as a reasonable source of availability data.
If you have questions about the Census EEO tabulations or any other OFCCP compliance matter, do not hesitate to contact us at BCGi@Biddle.com.