Contractors are required to design action-oriented programs to address any specific barriers to EEO that are identified during the contractor’s in-depth analysis of its total employment process. The programs should specifically describe who is responsible for implementing the program, what actions the contractor will take, and when and how the program will work.
For the programs to be effective, contractors must ensure that they are doing more than following the same procedures that previously produced inadequate results. COs must use the on-site review to gather the information they need to determine whether the contractor identified all the impediments to EEO.
The on-site review often illustrates the contractor’s compliance with this requirement when COs investigate other issues. For example, in requesting copies of position descriptions and discussing them with personnel, a CO can determine how recently the contractor reviewed the descriptions; if the descriptions are accurate; and if the contractor’s selection process screens for the knowledge, skills and abilities related to the position descriptions. If the descriptions are not accurate, this may be indicative of a problem area. Additionally, when the CO questions interviewees like the contractor officials, employees and third parties about the contractor’s recruitment and outreach efforts, the CO can obtain information related to the action-oriented nature and relative success of these efforts.