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Disaggregating Minority Groups for AAP Placement Goals

OFCCP’s Executive Order 11246 affirmative action program (AAP) regulations require contractors to establish a placement goal for a particular job group when it is underutilized – that is, when the percentage of women and/or minorities is less than would be reasonably expected given the representation of women and/or minorities available for employment in that job group.

1. What is a placement goal?

The placement goal serves as a target – not a quota or set-aside – that contractors must make good faith efforts to meet.

When a contractor finds underutilization of minorities in a particular job group, OFCCP’’s regulations require contractors to set a single utilization goal for all minorities. For example, a contractor may set a utilization goal for minorities if, as a whole, minorities comprise 40 percent of the qualified people available to work as mid‐level managers at a contractor’s establishment, but the percentage of minority mid-level managers actually employed at the establishment is only 5 percent. In that case, the contractor would typically set a single minority utilization goal in its AAP and make good faith efforts, such as through increased outreach and recruitment, so that over time the contractor’s workforce will generally reflect the labor pool from which it selects candidates.

While placement goals enable contractors to measure progress toward achieving equal employment opportunity, they do not provide contractors a justification for hiring preferences, they do not create set‐asides for particular groups, nor are they intended to achieve equal results. Also, placement goals do not require contractors to hire unqualified or less qualified candidates.

2. Does OFCCP ever require contractors to set disaggregated goals for particular minority groups?

In the event that the percentage of a particular minority group is substantially less than would be reasonably expected given the availability of that particular group, the regulations provide that OFCCP may require the contractor to establish separate goals for that particular group. Similarly, if the percentage of men or women of a particular minority group is substantially less than would be reasonably expected, then OFCCP may require separate goals for those underrepresented groups.

3. If separate goals for different race and ethnic groups are not required, may contractors nevertheless do so voluntarily?

Yes, as a best practice, OFCCP recommends that contractors set disaggregated placement goals for job groups when specific minority groups are underutilized. To do this, a contractor would categorize employees in each job group who identify as White, African‐American/Black, Asian/Pacific Islander, American Indian/Alaskan Native, and Hispanic. Then, as done for a single minority goal, the contractor would compare the percentage of qualified people available to work in the reasonable recruitment area to the number of employees in each job group, for each race or ethnic category. If the availability percentage is less than the percentage of employees in a particular category, the contractor would set a placement goal for that particular racial or ethnic group.

4. Must contractors also set a single, aggregated minority goal even if they set disaggregated goals?

Yes, even when setting disaggregated placement goals, contractors must continue to set a single, aggregate minority placement goal to comply with OFCCP’s regulations if minorities, in the aggregate, are underutilized.

5. When setting placement goals for specific minority groups, can contractors use the race and ethnic categories in the EEO‐1 Report?

Contractors can use either the race and ethnic categories set forth in 41 CFR 60‐2, or the categories set forth in the EEO‐1 survey submitted annually to the Equal Employment Opportunity Commission. This option is consistent with guidance OFCCP provided in Directive 2008‐02, "Federal contractors’ obligation to maintain and analyze the race and ethnicity data of applicants and employees in Affirmative Action Programs prepared in accordance with Executive Order 11246, as amended" (previously numbered Directive 283), issued on August 14, 2018.

6. What are some advantages to setting placement goals for specific, underutilized race and ethnic groups?

Utilizing disaggregated minority group goals can help contractors better target areas of their workforce in which there may be impediments to equal employment opportunity, and thereby use their resources more efficiently by, for example, tailoring outreach and recruitment efforts to specific groups that are underutilized.

7. Where can contractors learn more about determining availability and setting placement goals?

OFCCP’s regulations, in 41 CFR Part 60‐2, set forth the necessary steps contractors must take to determine the availability of women and minorities and to set placement goals. For instance, contractors should consider several factors for determining availability, such as the percentage of qualified women and minorities available to work in the reasonable recruitment area in addition to the percentage of promotable, trainable, and transferable women and minorities in the contractor’s workforce. To learn more about these and other factors for determining availability and setting placement goals, please see Chapter 1 of the Federal Contract Compliance Manual or OFCCP’s Sample AAP for Executive Order 11246.