AFFIRMATIVE EMPLOYMENT PROGRAM PLANNING

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AFFIRMATIVE EMPLOYMENT PROGRAM PLANNING
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Performance ratings in the EEO element must
include consideration of how supervisors actions
advance the Corps affirmative employment
objectives. Where imbalances or lack of progress
is evident, necessary measures will be taken to
remedy the problem.MVD Commanders Policy
Letter on Equal Employment Opportunity and
Affirmative Action
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Terminology

• Barrier Personnel principle, policy or practice
  which tends to restrict or limit the
  representative employment of applicants and
  employees, especially minorities, women and
  individuals with disabilities.
• Civilian Labor Force (CLF) Persons 16 years of
  age or older who are employed or seeking civilian
  employment.

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Terminology - continued

• At Parity When the percentage of the Divisions
  or Districts workforce, as applicable, of a
  specific Race/National Origin/Gender group is
  equal to their percentage in the relevant
  Civilian Labor Force.

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PATCOB Job Categories

• All job series are divided into PATCOB
  Categories. PATCOB stands for
• Professional,
• Administrative,
• Technical
• Clerical,
• Other, and
• Blue Collar.

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Job Categories

• Professional Occupations that have a positive
  educational requirement require knowledge or
  learning characteristically acquired through
  education equivalent to a bachelors or higher
  degree with major study or in a pertinent
  specialized field as distinguished from general
  education.

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Job categories - Continued

• Administrative Occupations that involve the
  exercise of analytic ability, judgment,
  discretion and personal responsibility and
  application of a substantial body of knowledge of
  principles, concepts and practices applicable to
  one or more fields of administration or
  management.

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Job Categories - Continued

• Technical Occupations that typically involve
  work associated with and supportive of a
  professional or administrative field, which is
  non-routine in nature and involves extensive
  practical knowledge gained through on-the-job
  experience or specific training less than that
  represented by college graduation.

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Job Categories - Continued

• Clerical Occupations that involve structured
  work in support of office, business, or fiscal
  operations performed in accordance with
  established policies, procedures, or techniques
  and requiring training, experience or working
  knowledge related to the tasks to be performed.

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Job Categories - continued

• Other Occupations that cannot be related to the
  above categories. These include Co-Ops (SCEPs),
  etc.

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Job Categories - Continued

• Blue Collar Occupations in a recognized trade
  or craft or in other skilled mechanical craft
  occupations that involve unskilled or semiskilled
  or skilled manual labor any other position
  having trade, craft or laboring experience and
  knowledge as a paramount requirement.

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Affirmative Employment Program Plan A
comprehensive personnel management program
designed to eliminate systemic barriers which
have caused under-representation of groups in
organizations and occupations.
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Affirmative Employment is NOT

• Hard and fast quotas.
• Preference for unqualified individuals.
• Mandatory selection of specific candidates.
• Forever. Once parity is achieved, AEPP ceases
  for that race/national origin/gender group.
• An infringement upon the rights of other
  employees.

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Which agencies must submit a plan?

• Agencies/Installations with 500 or more permanent
  employees.

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What Laws and Regulations Apply

• EO 11478 - Affirmative EEO Programs in the
  Federal Sector
• Civil Rights Act of 1972
• Civil Service Reform Act of 1978
• 29 CFR 1614
• EEOC MD 713 and 714

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Who do we count in our Plan?

• Full-time permanent employees
• Permanent seasonal employees
• Part-time permanent employees
• NOT COUNTED
• Temporary employees, including Student Aides
• Term employees
• Contract workers

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AEP Plan Development

• Prepare the required statistical charts
• Program Analysis
• Program Evaluation
• Action Items
• Barrier Identification

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Statistical Charts

• Gains and losses comparison from 1 October to 30
  September
• By PATCOB
• By Occupational Series with 100 or more and by
  pay plan and grade within each series.
• By pay plan and grade
• Net gains and losses by numerical goal

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Statistical Charts - Continued

• Comparison with relevant Civilian Labor Force
• By PATCOB
• By Occupational series with 100 or more

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Statistical charts - continued

• Standard Deviation analysis
• For Occupations with 100 or more in the District
• While not required, we also do it for PATCOB
  Categories.

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Program Analysis

• Narrative Program Analysis
• a. Organization and Resources
• b. Work Force
• c. Discrimination Complaints
• d. Recruitment and Hiring
• e. Employee Development Programs
• f. Promotions
• g. Separations

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Organization and Resources

• Do we have adequate manpower, fiscal resources,
  and time devoted to EEO.
• Are we providing training to supervisors and
  managers.
• Do we use incentive awards to reward EEO
  performance.
• Is there an EEO element in supervisors
  performance standards and ratings.

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Program Analysis - Workforce

• Statistical charts and narrative analysis of the
  workforce, broken down by job category, grade
  groupings and major occupational series.
• Narrative comparison with the previous years
  statistics.
• Narrative comparison with the available Civilian
  Labor Force (CLF)

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Program Analysis - Complaints

• Analyze complaints and their bases. Is there a
  problem area that needs attention?

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Program Analysis - Recruitment and Hiring

• Are our present recruiting sources yielding
  qualified applicants?
• Are our qualifications requirements and
  procedures impeding successful recruitment?
• Do our recruitment literature and display posters
  reflect a desire for diversity in the work group?

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Program Analysis - recruitment and Hiring
continued

• Do we advertise in minority media when we use
  paid advertising?
• What involvement do managers have in community
  groups interested in equal employment
  opportunity, resolving employment-related
  problems in the local community and community
  services?

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Program Analysis - Employee Development

• Have we done skills surveys?
• Do we know if some EEO groups get promoted faster
  than others, and if so why?
• Is career counseling available to everyone?
• Are efforts made to identify appropriate training
  for all employees regardless of grade or EEO
  group?
• Are employees encouraged to take advantage of
  educational opportunities outside of work?

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Program Analysis - Promotions

• Are all justifications for selections valid and
  employment-related with no unnecessary barriers?
• Are efforts made to ensure that appropriate
  promotional opportunities are available to all
  grades, occupational areas, regardless of EEO
  group?

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Program Analysis - Separations

• Are separations, including Reduction in Force,
  done fairly and in a non-discriminatory manner?

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Program Evaluation

• Have we incorporated findings from outside
  reviews into our plan?
• Do the SEPC, Personnel Officer, and management
  officials provide input into the EEO program
  evaluation?
• Do we have access to timely and accurate
  statistics?
• Are EEO Officials fully trained in EEOC and OPM
  regulations?

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Prevention of Sexual Harassment

• Is training conducted annually to inform
  employees of sexual harassment policies and
  actions to eliminate and prevent?
• Is training conducted to remind supervisors of
  their responsibilities?
• Are policy letters in place on sexual harassment?
• Are supervisors held accountable for sexual
  harassment in workplace?
• Is the workplace monitored to ensure compliance
  with sexual harassment policy?

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Action Items

• Action items are developed for any series with
  100 or more incumbents and any PATCOB category in
  which Race/National Origin/Gender groups are
  below parity.

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Barrier Identification - Step 1

• Problems or barriers must be in our control.
• Problems must be ones that we can eliminate
  within a five-year period.
• We must identify specific actions to eliminate
  each barrier or problem.

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Barrier Identification - Step 2

• Clearly state specific and measurable objectives
  .
• State specific action items that address the
  barriers identified in Step 1.
• Assign a specific responsible official by title
  for each objective and each action item.
• Set a target date (suspense) for each task.

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Numerical Goals

• Numerical goals are ONLY set for
• Specific occupational SERIES with 100 or more
  incumbents.
• Race/National Origin/Gender groups with two or
  more standard deviations from parity with the
  available Civilian Labor Force.

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Numerical Goals

• Numerical Goals may not be set for
• Non-minority men
• Any Race/National Origin/Gender Group which is at
  or ABOVE parity
• Any Race/National Origin/Gender Group which is
  NOT 2 or more Standard Deviations from Parity
• PATCOB categories, as a group

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Numerical goals

• Numerical goals do not require or mandate the
  selection of unqualified persons or preferential
  treatment based on race, national origin or sex.
  The purpose of numerical goals is to attain,
  rather than maintain, a balanced work force.
• EEOC Management Directive 714