We are pleased to present the next guide in our ongoing “OFCCP Compliance Primer” series, which is designed to help new compliance professionals understand the affirmative action program (AAP) requirements — enforced by the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) — that apply to companies doing business with the federal government. Each guide in the series, presented in a logical order, is designed to focus on a discrete aspect of the AAP, from why and how we prepare them, to how each element should be constructed to ensure compliance.
Our most recent guide focused on the “External Availability Report,” a document that details how a federal contractor calculates the percentage of qualified female and minority individuals in the relevant labor market. External availability is one of two factors contractors are required to consider when calculating the overall, or “final,” availability of women and minorities in comparison with the demographics of the contractor’s current workforce.
Because job openings can be filled by existing employees through transfers or promotions, contractors are also required to calculate the internal availability of women and minorities in the incumbent workforce. This guide focuses on how contractors are supposed to determine, or calculate, the internal availability for women and minorities, which typically will be reflected in an “Internal Availability Report.”
Members of the Equal Employment Advisory Council (EEAC) can read more here.