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The OFCCP enforces
Executive Order 11246, as amended. Under the Executive Order,
contractors and subcontractors with a federal contract of
$50,000 or more and 50 or more employees are required to develop
a written Director of Human Resources-Affirmative Action/Equal
Employment Opportunity program that sets forth specific and
result-oriented procedures to which a contractor commits itself
to apply every good faith effort. The OFCCP regulations
define a Director of Human Resources-Affirmative Action/Equal
Employment Opportunity program as: “a set of specific and
result-oriented procedures to which a contractor commits himself
(sic) to apply every good faith effort. To achieve prompt and
full utilization of minorities and women at all levels and all
segments of his workforce where deficiencies exist.” A Director
of Human Resources-Affirmative Action/Equal Employment
Opportunity program consists of three major parts. The first
part is a narrative that outlines duties and responsibilities.
The second part contains two main statistical analyses, with
several major subparts. The main statistical analyses are a
“Workforce Analysis” and a “Utilization Analysis.” While the
Workforce Analysis stands alone as a discrete document, the
Utilization Analysis consists of three identifiable statistical
subparts, including a division of the workforce into (a) “Major”
Job Groups, (b) Availability Analysis (the so-called Eight
Factor Availability Analysis), and (c) Goals developed if
“underutilization” is identified. This Director of Human
Resources-Affirmative Action/Equal Employment Opportunity
program contains the University’s responsibilities, identifies
areas of underutilization, and outlines strategies to address
the underutilization, in accordance with State and Federal
guidelines. |