COs must review the contractor’s written AAPs to find information on the selection processes that may apply to positions above and below the grades/levels where participation by nonfavored groups declines. As an example, a CO would look for information on the contractor’s promotion policy. If the policy is to limit management jobs to internal candidates, the corporation should also have policies and procedures for making these job openings known to potential internal candidates within corporate headquarters and outside of headquarters. Other instances where policies may indicate a problem might include the absence of employee development programs that apply to positions above and below the grades/levels where nonfavored group member participation declines. The absence of outreach efforts designed to improve access to management positions for nonfavored group members could also be a problem.
COs must also use personnel activity data from the contractor’s AAP to identify the employment activities that include jobs above and below the level where nonfavored group member participation declines. This is in addition to conducting analyses on employment activity data. The CO must identify the number of hires and applicants at, above and below the grade where nonfavored group member participation declines. Based on the available data, the CO will determine how jobs at and above that level are filled (e.g., hired from the outside, or promoted or transferred from within). Proper analysis may require requesting additional data and gathering information during the on-site review. Useful information related to this section is in FCCM 4F, Notice of On-site Review and Follow-up Data Requests and FCCM 4H, On-site: Filling of Management Jobs.
Now the CO must next compare the number of hires, promotions and transfers at, above and below the grade where nonfavored group representation declines. The CO must also identify terminations of nonfavored group members above and below the grade where their participation declines.
Once this is complete, COs must address all areas of potential concern in the SCER.