The first step in analyzing the contractor’s use of objective selection criteria is to verify that the criteria were actually used to make selections, and that they were applied uniformly to all members of the favored and nonfavored groups. COs only need to consider the contractor’s stated legitimate objective criteria.
a. Single Criterion. To examine the application of the criterion, the CO must determine whether the same criterion was applied to each individual and that data reflecting the application of the criterion are available for all individuals in the relevant pool.
b. Multiple Criteria. When there are multiple criteria, or there is no summary record available to determine whether the people selected met the criteria, the CO will need to create a summary record. The CO can do this by creating a spreadsheet or a database that contains all relevant data for each individual applicant or candidate, or both. Based on the example in subsection 2M01(a) above, the spreadsheet data for each applicant would include race, ethnicity, sex, high school diploma or no diploma, test result and interview result. The spreadsheet will allow the CO to analyze the data more readily and determine whether the multiple criteria were applied uniformly to each applicant and the result of their application (e.g., the applicant or candidate was either selected or not selected).
c. Interpreting the Results of Criteria Verification.
- When the review of individuals selected is complete, the CO must review the spreadsheet data to see if each selectee actually met the criteria. The CO may conclude that the contractor used the criteria if everyone selected met the criteria.
- If a substantial number of individuals selected do not meet a particular criterion, the CO may discount the contractor’s statement that the criterion was the basis for the decision.
- If the contractor used the criterion in a nonuniform manner, the CO must determine whether the contractor applied the criterion differently to members of the favored group when compared to the nonfavored group. This comparison will reveal any disparate treatment.
- If the contractor applied the criterion uniformly to members of the nonfavored group and favored group, then the CO must analyze the effect of the application of the criterion for adverse impact.