Six Things You Should Know About Affirmative Action Plans

Document created by 1050210 on Nov 16, 2014Last modified by 1054638 on Nov 18, 2014
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Published Date: 10/13/2014


By Kaleigh Ferraro


If your organization provides goods or services to the federal government either directly or indirectly, you may be subject to affirmative action regulations. Just in 2014, regulation changes regarding affirmative action programs for protected veterans and individuals with disabilities became effective. President Obama has also signed several Executive Orders affecting federal contractors. Is your organization in compliance with these recent and proposed changes?


Q: Are you covered as an affirmative action employer?
A: If you have federal contracts or subcontracts of at least $10,000, you are covered under the affirmative action regulations.


Q: What are the affirmative action requirements?
A: One of the main requirements is to annually develop written affirmative action plans if you have federal contracts or subcontracts of $50,000 or more and 50 or more employees. There are a number of other requirements as well.


Q: What is the impact of the changes to organizations regarding protected veterans and individuals with disabilities?
A: Some of the major changes that became effective in 2014 require setting hiring benchmarks for veterans and utilization goals for individuals with disabilities. They also require federal contractors to solicit self-identification of applicants for veteran and disability statuses prior to a job offer.


Q: What type of data is needed to develop an affirmative action plan?
A: In order to develop an annual affirmative action plan, you will need a current listing of employees. This employee listing will be used to determine if Placement Goals must be established for women and minorities. This listing will also be used to determine if utilization goals for individuals with disabilities are met. Contractors must also review employment decisions for hires, promotions and terminations for the 12 months prior to the employee listing.


Q: What is required of affirmative action employers other than the written affirmative action plan?
A: There are a number of additional requirements beyond an affirmative action plan. These requirements include the following: recordkeeping requirements, tracking applicant data, annually filing EEO-1/VETS-100A reports, notifying subcontractors and vendors of obligations, specific language in covered purchase orders and subcontracts, listing jobs with state employment service delivery systems, outreach and recruitment efforts, etc. CAI can provide additional information regarding these and other requirements.


Q: What are the recently signed Executive Orders and proposed regulation changes?
A: President Obama has signed several Executive Orders in 2014 that may lead to changes for federal contractors and subcontractors. They include:


  • establishing higher minimum wages for federal contractors
  • expanding affirmative action requirements to include gender identity and sexual orientation as protected groups
  • protecting workers from retaliation when discussing pay with other employees


The OFCCP also issued proposed regulations that would require contractors to submit compensation information annually in an expanded Employer Information Report EEO-1.


We are hosting a webinar that will highlight the details of all these recent changes – Affirmative Action: A Year in Review – on Wednesday, October 22 from 10:00 am to 11:00 am. Register today at


You can also contact me directly at 919‑713‑5241 or for additional information or with other affirmative action questions..