Affirmative Action - Two Factor Analysis

Federal contractors with contracts of at least $50,000 and with 50 or more employees are required by Executive Order 11246 [enforced by the Office of Federal Contract Compliance Programs (OFCCP)] to have an Affirmative Action Plan (AAP). As part of such a plan, contractors must analyze all major job groups within their work forces to determine if minorities and/or women are being under-utilized. Previously, in determining availability, a contractor considered each of eight factors listed in the regulations. Although contractors were required to consider all eight factors, they were not required to utilize each factor in determining the final availability estimate. Only the factors relevant to the actual availability of workers for the job group in question were to be used. Most contractors actually used only a few of the eight factors to compute final availability estimates. Therefore, this regulation has been revised by the OFCCP. The availability computations have been simplified by reducing the number of factors from eight to two. These two factors are the same for minorities and for women.

Factor 1
Determine the percentage of minorities or women with the requisite skills in the reasonable recruitment area.  The reasonable recruitment area is defined as the geographical area from which the contractor usually seeks or reasonably could seek workers to fill the positions in question. This information can be obtained by using the online 2000 Census EEO Data Tool application (see information below).

Factor 2
Determine the percentage of minorities or women among those promotable, transferable, and trainable with the contractor's organization. Trainable refers to those employees within the contractor’s organization who could, with appropriate training that the contractor is reasonably able to provide, become promotable or transferable during the AAP year.  

Contractors would be required to determine the percentages by undertaking one or both of the following steps:

• Determine which groups are "feeder pools" for the job group in question. The feeder pools are job groups in which individuals are promoted.
   

• Ascertain which employees could be promoted or transferred with appropriated training which the contractor is reasonably able to provide.

For more information

For additional information regarding Affirmative Action policies, refer to the Office of Federal Contract Compliance Programs (OFCCP) website.

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If you have questions or need more information, contact Bernie Moran of the Labor Market Information Center at (605) 626-2314 or e-mail her at bernie.moran@state.sd.us.