Your Affirmative Action Plan’s focus on compensation, and 6 common mistakes

 

If your organization has built or is building an Affirmation Action Plan, Tamara Seiler has great insight for government contractors to comply with requirements and compete for government funding, as well as leverage the data you are required to collect to improve your recruitment efforts. Seiler is Director of Compliance and Marketing Strategy at HudsonMann, and she is very familiar with challenges and trends related to affirmative action. 

An increasing focus on compensation

“In the absence of discrimination, over time, your workforce will generally reflect the gender, racial, and ethnic profile of the population from which you recruit.” That is the central premise of affirmative action, according to HudsonMann. An Affirmation Action Plan (AAP) is a requirement to be a federal contractor. “To get government money,” says Seiler, there are criteria you must meet, as far as “the incumbency of your workforce versus the availability.”

Seiler says, “A growing focus that we’re seeing through audits, which is a clear delineator, is compensation.” The Office of Federal Contract Compliance Programs (OFCCP) is increasingly focused on compensation by looking at increased fair pay reviews among employees. Starting pay is critical because variances in early pay tend to grow with time. Consistency in recruiting “can help rectify that,” says Seiler.

A growing focus that we’re seeing through audits is compensation. The focus on compensation by the OFCCP is increased fair pay reviews among employees, and it starts with starting pay.

Analyzing your systems and processes more rigorously should be part of your organization’s overall inclusion efforts. Even if your organization doesn’t have the regulation requirement to do a written AAP, your systems can still provide the metrics needed to illustrate how you’re recruiting as well as compensation structures

Determining starting salary 

“As of July 10, there were 10 states and eight local bans prohibiting asking previous salary information, which is causing employers to do a more detailed analysis of market trends. There are many variables that impact salary.” Seiler advises her clients to look beyond the job description. Look at your market, your industry, your location, go to glassdoor, and “find out for your industry, for this job title, for where you’re located, what is the average?” She admits there are a lot of variables that make a full analysis “cumbersome,” for example, the experience of the candidate, nonprofit or for-profit, size of the organization, what benefits are offered, etc.

Related: Recruiting diverse entry-level talent: Interview with Kathryn Christie

This internal analysis, however, is critical because “comp is becoming such a huge focus for the OFCCP when they’re doing an audit.” And everything has to be verifiable, she adds. “Make everything as objective as possible.” Eliminate, as much as you can, all subjective aspects in the application process “so that it is cut and dried.” For example, says Seiler, one person on the hiring committee may think an applicant was well spoken. Another person may not agree. Your team needs to agree on objective measures to evaluate a candidate’s qualifications.

How your AAP can help determine new recruiting efforts

In a written AAP, Seiler looks for “adverse impact in hiring, adverse impact in terminations, and promotions against protected classes. So that’s women, minorities, and as of 2014, individuals with disabilities. We have an outreach responsibility for veterans as well.” Seiler says these data help federal contractors to see where they have disparities between what they have in their workforce and what’s available in their recruiting area. To do targeted outreach, “try to get your jobs in front of the people that are in your communities from where you are hiring.”

6 recruiting mistakes when building or using an AAP

Seiler has seen and heard many mistakes in recruitment, and learned from making some of these herself. These are the six most common she sees.

1. Build a more a diverse network. “We talk about that every day with our clients. The OFCCP requires targeted meaningful outreach. That’s one on one outreach. […] The OFCCP will actually pick up the phone and call the people on their outreach log.” Seiler adds, “The more diverse your network, the more diverse your applicant pools are.” One obstacle to successfully diversifying an organization is that most employers look at diversity and inclusion backwards. Think of inclusion first, and diversity second. Seiler says,“If you’re an inclusive organization, you’re going to have diversity.”
2. Make sure to disposition every applicant. “Yes, it does take time. In an audit, they can request information up to three years old. I don’t know about you, but as I’ve gotten older it’s hard to remember exactly why Jane Doe didn’t get selected over John Doe.” Make sure to document why each candidate falls out of the hiring process.
3. “Don’t become too invested in an applicant. This can lead to frustration when they don’t show up for an interview or a call back. We can all remember that one applicant that we advocated almost to the point of getting terminated because they were the person, and then they didn’t show up.
4. “One of the things that I was guilty of early on was ‘recruiter rut.’ You think you have this master strategy for recruiting, and you can’t figure out ‘Why am I not getting this?’ Change up your recruiting strategy.” Go back to your team and share, Seiler advises. Ask where others are succeeding and learn new best practices.
5. “Follow up regardless of the applicant’s status. Follow up and let them know their status. While he or she may not have received an offer, they’ll remember that you treated them with respect by letting them know that they were not selected. […]Word of mouth can make or break a company.” Taking a second to generate an email to those applicants can keep you from building a negative reputation.
6. “Don’t forget to keep learning. Keep your knowledge of technology up to date. It changes every 30 seconds. Master your position. And find a mentor who can either help you with this, help you find your passion. You may think you know your strengths, but […] sometimes your mentor puts you in a new direction because they’re seeing your strengths.”

Becoming inclusive after completing an  AAP

After doing the AAP, Seiler says “that’s when the fun begins,” At this point, dig deeper into your processes, look at your goals and especially those that you didn’t meet last year and discuss where to step up your recruiting.

Related: Workplace engagement, millennial expectations of inclusion, and concrete tips for managers

“The plans basically just serve as an important baseline. The annual review is to ensure nondiscrimination. So then we go the intentional targeted, meaningful outreach. And then internal inclusion efforts are the next step.” Seiler sees her clients competing for government funding, so “by doing these diversity metrics they can show progress year to year.”