How to Establish a Federal Contract Compliance Program
- 1). Search your accounts receivables and sales contracts to determine if you provide more than $10,000 in products or services to the federal government. This amount can be a single purchase by a federal agency, or the total amount of products and services to more than one agency during a one-year period. Executive Order 11246 (E.O. 11246) requires contractors that meet this threshold to develop an equal opportunity statement and practice nondiscriminatory employment and purchasing practices. If you do not meet the purchasing requirement, then your company is probably not considered a government contractor. But it's good business practice to include a standard equal opportunity employment (EOE) statement in your employee handbook, company literature and in common areas throughout the workplace.
- 2). Ask your human resources information systems (HRIS) staff or a member of the IT department to generate an employee roster sorted by work site location, race, sex, age, veteran and disability status. Search your accounts receivables and sales contracts again to determine if you have 50 or more employees and provide more than $50,000 per year in products or services to any federal government agency. In the event that you anticipate government business that meets or exceeds this threshold, you are required to publish a written affirmative action plan. Written affirmative action plans must be updated annually.
- 3). Study the federal regulations pertaining to affirmative action plans. The U.S. Department of Labor Office of Federal Contract Compliance Programs (OFCCP) posts extensively on its website recommendations for effective affirmative action plans (AAPs). You can locate sample AAPs and resources for technical guidance on preparing your company's AAP. Pay careful attention to the required components of an AAP. An accurate, detailed and sorted employee census report is essential for analyzing employment data. AAPs require analyses pertaining to fair employment based on variables such as race, ethnicity, sex, veteran and disability status.
- 4). Analyze your company's data, using the Federal Contract Compliance Manual (FCCM) for easy reference. Developing your first AAP will be challenging because of the type of detailed data required from other sources, such as your state's labor market statistics, definitions of U.S. Equal Employment Opportunity Commission job categories and information concerning outreach methods for attracting a diverse pool of applicants. You must refer to OFCCP regulations at every step of your work force analysis until you become familiar with the regulations.
- 5). Schedule meetings with supervisors, managers and executive staff to explain the purpose of a federal contract compliance program, or AAP. Ensure they understand the meaning of affirmative action and why it's important to promote the organization as a company that values equal employment opportunity. Provide everyone on the leadership team with a copy of the finalized AAP and schedule a time to reconvene to discuss the elements of the AAP and how supervisors and managers will be held accountable for adhering to the EEO policy endorsed by company executives.
Source...