The contactor’s in-depth analysis of its total employment process in its AAP should indicate whether and where impediments to EEO exist based on its utilization, personnel activity (e.g., applicant flow, hires, terminations, promotions, other personnel actions), compensation analysis, and selection procedures. In evaluating these employment processes, COs determine whether there are any disparities based on race, sex or ethnicity.
During interviews with individuals who contributed to the development and implementation of the AAP, and individuals who are involved in the hiring or selection process, COs must discuss the contractor’s identified problem areas to determine how the contractor identified each problem, the scope of the problem, what solutions the contractor implemented and the effectiveness of the actions taken.
COs must also specifically examine records on the contractor’s employment activity, and selection criteria and processes to understand the contractor’s total employment process, and verify whether the contractor identified all of the impediments to EEO. Questions that may be useful to COs are provided below.
- Did the contractor review its selection criteria?
- Did the contractor apply the criteria in a nondiscriminatory manner and determine whether the selection criteria might have an adverse impact?
- Did the contractor perform validity studies on any criteria found to have an adverse impact, and did the contractor properly determine the criteria to be job-related and consistent with business necessity?
- How frequently does the contractor review selection criteria?
- How does the contractor document the review?
- Do the contractor’s efforts comply with the UGESP at 41 CFR Part 60-3?
- Did the contractor ensure that the officials and managers responsible for applying selection criteria and procedures are familiar with, and are implementing, the contractor’s EEO policies? Does the contractor provide training? If so, how frequently is training provided?
In its AAP, the contractor should identify concentrations and absences of any specific protected group within its workforce. During the on-site review, COs must seek to identify any job titles for which there are significantly high or low representations of any protected group. COs must incorporate questions regarding these circumstances into the interviews with the contractor’s supervisors and employees.
COs must remember to record either their confirmation or description of problem areas identified in Part B of the SCER. The SCER must also include a description of any identified or implemented problem resolutions.