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Key Takeaways: Developing Job Groups, Determining Labor Areas, and Assigning Census Codes: It Pays to Take a Closer Look

October 24, 2018 By Michael Pati

On October 17, 2018, BCGi presented a webinar on Developing Job Groups, Determining Labor Areas, and Assigning Census Codes: It Pays to Take a Closer Look. This presentation was designed for both people who may be new to AAP development as well as experienced practitioners.

Below are some of the key highlights:

Job Groups

  • A Job Group is an aggregation of jobs that are similar in content, wage and opportunity, and is the basic unit of analysis in an AAP.
  • When designing job groups, begin by aligning jobs according to their EEO categories.
  • If you are a small employer (i.e., less than 150 employees) you may use the EEO categories as your AAP job groups.
  • The regulations do not require job group categories to be a particular size.  So discretion may be used when forming a job group that is large enough to allow for meaningful analysis, but not so large you are combining jobs that are significantly different from one another.
  • It is acceptable to have job groups with only a handful of employees or less if that is how many you have in a given EEO category.  For example, if you only have one employee in the Service Workers category, do not combine it with another category for the sole purpose of creating a larger sample size.
  • When designing more refined job group categories, you may want to consider aligning positions by specialty/family (e.g., Engineers, Customer Service Reps, Finance, Nursing, etc.) or job level (e.g., Senior, Mid and Entry-Level).
  • The structure and composition of the job groups have a direct effect on the calculation of the final availabilities/goals, on the utilization, disparate impact, and compensation analyses.

Availability Analysis

  • The Availability Analysis is meant to reflect “who you should have” as a percentage of qualified women and minorities available to work in positions at your organization.
  • Two important elements to consider when calculating availability are the Geographic Recruitment Area (“where you recruit from”) and External Source Data (“who is qualified to work at positions in your establishment”).
  • In order to accurately create recruitment areas, consider leveraging both a data-driven approach (via an employee or applicant zip code analysis) as well as HR staff that is knowledgeable about the company’s recruitment practices.
  • The 2006-2010 EEO Tabulation occupational census data are most commonly used source and is widely accepted by OFCCP.
  • There are other external sources that may also provide relevant data, such as the Civilian Labor Force, census data that are Industry-Specific or separated by Earnings, or data on Educational Attainment.
  • There are pros and cons to using all external data sources. Evaluate the available data and select the external source – or a combination of them – that most accurately reflects the types of jobs being filled at your organization.

We hope everyone enjoyed the presentation! If you missed it, don’t worry, there are plenty of other great webinars coming up! Please be sure to check the BCGi calendar!

Key Takeaways: “VETS 4212”

July 27, 2018 By Dao Nguyen

On July 18th Dao Nguyen and Michael Pati presented the webinar VETS-4212, which covered important basics about the annual reporting required by the Veterans’ Employment and Training Service (VETS) Office. Below are some of the key highlights:

Who must file: All federal contractors and subcontractors who have a federal contract or subcontract of $150,000 or more entered into or modified after October 1, 2015. It is important to note that there is no threshold for the number of employees.

When to file: The VETS-4212 online reporting application is scheduled to open on August 1st and the deadline to file is on September 30, 2018.

Reporting Period: For this filing period, contractors may select:

  • any payroll period ending between July 1 and August 31, 2018; or
  • December 31, 2017, for contractors who received approval to use that date for purposes of filing their EEO-1 report(s).

In addition, contractors must also report new hires that occurred during the 12-month period immediately preceding the selected snapshot date (https://www.dol.gov/vets/contractor/main.htm#14).

Reporting Information:

  • Total number of employees and new hires by job EEO category and hiring location;
  • Numbers of employees and new hires who identified as being a protected veteran
  • Address of each hiring location
  • Other company identifying information such as VETS Company Number (for returning filers only), NAICS, Dun and Bradstreet, and Federal Employer/Tax ID.

How to File:

  • For first time filers, register at https://vets4212.dol.gov/vets4212/External/Registration
  • For returning filers, new passwords may be obtained at https://vets4212.dol.gov/vets4212/Account/ResetPassword, and will need to be reset every 60 days.
  • Options to file: Reporting may be completed by Manual Input or Batch Filing in the VETS Online Filing System; or by completing the downloadable 2018 Fillable Form (https://www.dol.gov/vets/programs/fcp/vets-4212_rev_2018.pdf) and submitting via email to VETS4212-customersupport@dol.gov.

A recorded version of the webinar, which includes the live demonstration of creating pivot tables for the VETS-4212, is available to our Platinum members.

To log in and access this and other past webinars, or to learn more about the benefits of becoming a member, please visit BCGi’s website. You may contact us via email staff@biddle.com or call (800) 999-0438 for any questions.

Contributing author: Michael Pati, Practice Manager, Silicon Valley at Biddle Consulting Group, Inc.

Key Takeaways: “Foundations of AAP Development”

April 9, 2018 By Diana Sicari

On March 29th, 2018, BCGi presented a webinar on the Foundations of AAP Development. This presentation, while designed primarily for people with zero to very little AAP experience, also contained information that even seasoned professionals would find useful when brushing up on AAP regulations. We focused on the fundamentals of AAP development, as well as best practices for compliance and audit success.

While the regulations spell out exactly what reports you need, they offer little guidance on how to go about creating the reports and analyses. The first half of the webinar focused on the essential components of creating an AAP from the ground up. We covered the reports required by the regulations and also some strategic planning, such as, how to determine how many AAPs your organization needs and how to set up an availability analysis.

The second portion of the presentation focused on best practices for compliance and audit success. Not only is it imperative that your organization is consistently collecting the correct and required information it is also necessary that all your organization’s policies and personnel processes should be analyzed for compliance. To assist, we created a Best Practices Checklist (provided as a handout for this webinar). Though it won’t do the work for you, it will ensure that you’re aware of each regulatory component and it will get you thinking about what areas within your organization might need some attention.

We hope everyone enjoyed the presentation! If you missed it, don’t worry, there are plenty of other great webinars coming up! Please be sure to check the BCGi calendar!

Contributing author: Oscar Martinez, EEO/AA Analyst I at Biddle Consulting Group, Inc.

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