Affirmative Action: Internal AAP Checklist


January 9, 2015
  • [Editor's note: On August 27, 2013 the Office of Federal Contract Compliance Programs (OFCCP) announced new rules outlining how federal contractors should handle their affirmative action and nondiscrimination obligations for protected veterans and for individuals with disabilities. These rules, in large part, mirror each other and fundamentally alter the rules for compliance with Section 503 of the Rehabilitation Act of 1973 covering persons with disabilities and The Vietnam Era Veterans’ Readjustment Assistance Act which governs protected veterans.

The changes include:

  • Applying the “internet applicant” rule to the new rules so that electronic applications and inquiries will be handled the same way they are handled for other groups covered by affirmative action (race, color, religion, sex or national origin); Changing the 2-year record-keeping requirement to 3-years; Removing the requirement in the disabilities rule to review all physical and mental job qualification standards on an annual basis and replacing it with a requirement for contractors to establish their own schedule for reviewing job qualifications.
  • Although some aspects of the rules were made less onerous, the final versions of both rules include significant requirements for employers. Under each rule, the OFCCP requires employers to achieve specific numeric goals to document compliance. For example, the final disabilities rule still requires that 7 percent of all persons in each of the organization’s job groups be individuals with disabilities. It also requires that contractors compare the number of individuals with disabilities (IWD) who apply to the number of IWD that are hired, and keep those records for three years for audit purposes.]


  • Developed equal employment opportunity (EEO) policy statements and communicated the AAP for minorities and women, veterans and disabled with all managers and supervisors at all levels to ensure that the policy is understood and followed in all employment actions.
  • Audited the contents of the company’s internal and external communications to ensure compliance information is posted and up-to-date (e.g., job descriptions, online and print job advertisements, affirmative action posters).
  • Reviewed recruitment, advertising and job application procedures to ensure nondiscrimination and equal employment opportunity.
  • Posted job with state workforce agency job bank or with the local employment service delivery system where the opening occurs to satisfy the requirement to list jobs with the appropriate employment service delivery system.
  • Reviewed hiring, promotion, upgrading, award of tenure, layoff, recall from layoff processes to ensure nondiscrimination and equal employment opportunity.
  • Reviewed rates of pay and any other forms of compensation including fringe benefits to ensure nondiscrimination and equal employment opportunity.
  • Reviewed job assignments, job classifications, job descriptions and seniority lists to ensure nondiscrimination and equal employment opportunity.
  • Reviewed paid leave, leaves of absence or any other leave policies to ensure nondiscrimination and equal employment opportunity.
  • Reviewed training, apprenticeships, attendance at professional meetings and conferences, and any other term, condition or privilege of employment to ensure nondiscrimination and equal employment opportunity.


  • Maintained applicant flow log showing the name, race, sex, date of application, job title, interview status and the action taken for all individuals applying for job opportunities.
  • Maintained summary data of external job offers and hires, promotions, resignations, terminations, and layoffs by job group and by sex and minority group identification.
  • Maintained summary data of applicant flow at least identifying total applicants, total minority applicants and total female applicants for each position.
  • Maintained employment applications (not to exceed two years). Records that must be retained include, for example, advertisements, job postings, applications, resumes, interview notes, requests for reasonable accommodations, tests and test results, personnel files, rates of pay and other compensation, selection for training or apprenticeship, and other information regarding hiring, transfers, promotions, layoffs and terminations.
  • Maintained records pertaining to company compensation design and system.


  • Completed quarterly reports documenting company’s efforts to achieve its EEO/AAP responsibilities.
  • Managers and supervisors reported any current or foreseeable EEO problem areas and outlined their suggestions/recommendations for solutions.HR manager discussed any problems relating to significant rejection ratios, EEO charges, etc., with senior management.
  • HR manager reported the status of the company’s AAP goals and objectives to senior management.
  • HR manager recommended remedial actions for the effective implementation of the AAP.
  • Filed EEO-1, VETS 100 and VETS 100A reports annually.

Affirmative Action Plan Contents

  • Organizational profile including the following:
  • Job group analysis listing of all organizational units job titles, EEO-1 or OFCCP regulation race category, and job group name.
  • Utilization analysis including the following:
    • Placement of incumbents in job groups by number and percentages of females and minorities.
    • Determine availability for each job group by percentage of minorities or women and veterans or disabled with requisite skills in the reasonable recruitment area. Also determine percentage of minorities and women among those promotable, transferable and trainable within the company's organization. (Provide raw statistics, value weight, weighted statistics, source of statistics, reason for weighting.)
  • Comparison of incumbency percentages of females and minorities to availability for each job group.
  • Placement goals established, reasoning indicated. [Example: If the female/minority incumbency percent (%) is less than the female/minority availability percent (%) and the ratio of incumbency to availability is less than 80%, a placement goal was created for that job group.]
  • Additional required elements:
    • Designation of responsibility for implementation of affirmative action program.
    • Identification of problem areas and action-oriented goals established.
    • Internal audit and reporting system established.
  • Support data included for all job groups by race and gender categories including external hires, external applicants, promotions into job group, promotions within job group, voluntary terminations and retirements, involuntary terminations, layoffs, and recalls.
  • Applicant flow log included with candidate names, race/ethnicity, gender, date of application, job title, interviewed (Y/N), action taken and date (H/NH).
  • Analysis of affirmative action program progress from prior year AAP to current year AAP. Analysis is by job group, female and minorities goal placement rate percentage and actual placement rate percentage, and analysis of good faith efforts.
  • Other additional programs (optional).

The following guidelines established for nondiscrimination because of religion, national origin, veteran status or disabilities:

  • Policy statement—equal employment opportunity.
  • Review of personnel processes.
  • Review of physical and mental job duties.
  • Reasonable accommodation.
  • Harassment prevention and prohibition against retaliation.
  • External dissemination of EEO policy.
  • Internal dissemination of EEO policy.
  • Audit and reporting system.
  • Establishment of responsibility for AAP implementation.
  • Training to ensure AAP implementation.
  • Sample invitation to self-identify.

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