Job Group Assignment Can Have a Major Impact on Analysis Results

Job Group Assignment Can Have a Major Impact on Analysis Results
by Dao Vang, EEO Analyst

In the EEO industry there are many different types of companies, and with such diverse organizations it is expected that the methods they employ to approach affirmative action can be very different. While many place great importance on the creation and implementation of their Affirmative Action Plans, it is equally common for AAP development to become an annual exercise that has little impact on the organization. Unfortunately, some contractors only take their AAP and its corresponding obligations seriously when faced with an OFCCP audit.

While a lack of interest in creating and implementing proper AAPs has many drawbacks, one major issue is the creation of defensible job groups. We will call upon an example where a company (let’s call them Company XYZ) had been using the same AAP job groups for years. Company XYZ was aware that their AAP job groups needed significant revisions but it had yet to become a priority. Although as consultants we had pleaded with Company XYZ to work with us on redefining the job groups, and the client intended to make the necessary changes, they unfortunately did not make the time or provide the resources to make reassigning jobs a priority. As a result the project remained on the back burner for too long. The same concern had been revisited and mentioned by BCG each year, however, the restructuring of the job groups remained a “not so important task” from the client’s point of view. Not surprisingly, the excuses continued and the convenience of not making any changes won out for several years. Therefore, Company XYZ knowingly continued to use flawed job groups for their AAPs.

Then along came the day when Company XYZ received a 30-day scheduling letter from the OFCCP. Naturally, several of their job groups had adverse impact in hiring against females and/or minorities and lo-and-behold the overhaul of job group assignments suddenly became top priority. The rushed review confirmed two issues that the consultant already suspected: 1) some jobs were inappropriately grouped together (for example, technical and administrative professional jobs are in the same job group); and 2) there are job groups that could be split into more appropriate groups without sacrificing appropriate sample size.

Needless to say, when more appropriate job groups were created, the number of potential problem areas dropped dramatically. Unfortunately, the lesson learned was that the undertaking of job reassignments during a desk audit caused tremendous stress for everyone. In order to accommodate the newly created (but more appropriate) job groups, the current AAP had to be re-created, the previous year’s availability and placement goals reports were also re-created, and new adverse impact analyses had to be conducted --- all within the 30-day allotted period for the AAP submission.

From the consultant’s point of view, AAPs should be used as a diagnostic tool to determine whether potential problem areas exist in an organization. It should be obvious that plan results are only as good as the job title to job group assignments that they are based upon. Having pointed that out, here is some advice when creating AAP job groups:

o The jobs in each job group should have similar content, opportunities, wages, level, and responsibilities
o Job Groups should not reflect more than one EEO Category
o There is no minimum sample size requirement for each job group. However, there should be enough individuals in each job group to yield meaningful results
o For contractors with 150 employees or less, the regulations state that they can use EE0-1 Categories to as job groups (http://www.dol.gov/esa/ofccp/scaap.htm)
o Creating and dividing larger job groups or EEO categories into sub job groups are common. Consider creating sub job group by skill level or/and specialty (e.g., lower level managers, mid level managers, and upper level managers).

If you have any questions about creating job groups please e-mail BCG at staff@biddle.com