Main Office: 972.369.0015
AAP PREPARATION

KAIROS SERVICES, INC. staff has extensive experience in both the public and private sectors. Many are former compliance specialists and managers with the Office of Federal Contract Compliance Programs (OFCCP), the Federal regulatory agency responsible for affirmative action compliance by Federal contractors. Each AAP is prepared from the perspective of an OFCCP Compliance Specialist auditing the AAP. Therefore, we give attention to every detail in developing AAPs because we expect them to stand up to the rigorous scrutiny of an OFCCP audit.

Unlike consultants that may take a “cookie cutter” or “cut and paste” approach in preparing AAPs, KAIROS SERVICES, INC. professionals work closely with our clients to ensure that the data on which the AAP is based is complete and accurate. Any discrepancies in the data are thoroughly discussed and resolved prior to preparing the AAP.

Timeliness is important to our customers. The earlier the AAP is in place, the sooner a company can implement an effective program, address issues and develop strategies for goal accomplishments. We prepare AAPs within 30 days of receipt of complete data from our clients but often can prepare them as soon as one week from receipt of data for priority situations.

AAPs include the following:

Narrative components for each of the three AAPs required by Executive Order 11246, Section 503 of the Rehabilitation Act and the Vietnam Era Veteran’s Readjustment Assistance Act (38 U.S.C. 4212).

Statistical components for Executive Order 11246 AAPs including:

  • Organizational Profile/Workforce Analysis
  • Job Group Analysis
  • Job Group Census Composite Calculations
  • Availability Analysis
  • Comparison of Incumbency to Availability
  • Placement Goals for the Current AAP Year
  • Report on Results of Prior Year AAP Placement Goals
  • Applicant, Hire, Promotion and Termination Summaries
  • Impact Ratio Analysis for Hires, Promotions and Terminations

A Confidential Executive Briefing Report, an important risk management tool, is prepared for each AAP advising the client of existing and potential problem areas identified during the preparation of the AAP, addressing issues of adverse impact and under-utilization, identifying deficiencies or discrepancies noted in the required record-keeping of the documents used by a facility, and reporting any other potentially problematic policies, procedures or practices.

OFCCP AUDIT SUPPORT SERVICES
All of our auditors have extensive OFCCP as well as private sector backgrounds in affirmative action, EEO and workforce diversity compliance.

KAIROS SERVICES, INC. audit services focus on the following four-stage audit process:

  • Pre-OFCCP Desk Audit
  • Pre-OFCCP Onsite Audit
  • Onsite Technical Assistance During the Regulatory Audit
  • OFCCP Offsite Audit (Including Post Onsite Audit Activity)

The Pre-OFCCP Desk Audit and Pre-OFCCP Onsite Audit conducted by our experts replicate OFCCP procedures and methodology. Our audits include, inter alia, facility inspections, detailed review of employment policies and practices, verification of documents that serve as the basis of the AAP, I-9 inspections, accessibility evaluations, investigation of adverse impact determinations, interviews with employees and managers, and other related areas. The focus of our audits is on identifying actual and/or potential problem areas that OFCCP may likely find and correcting those problems before the regulatory agency identifies them. Our staff is also available to our clients during the OFCCP’s onsite and offsite review to assist in every phase of an audit.

If you are already in the midst of an audit going awry, we can help. Call us!

CONSULTING SERVICES
KAIROS SERVICES, INC. provides other consulting services in various areas that include, but are not limited to, the following:
  • Conduct a mock OFCCP audit to identify problem areas of potential discrimination and develop corrective action plans
  • Review and evaluate current or past AAPs for compliance
  • Prepare Summary Reports identifying non-compliant areas and other areas of concern along with recommendations for corrective action
  • Conduct compensation analyses
  • Represent contractors at negotiation/conciliation meetings with OFCCP
  • Research issues related to affirmative action and EEO
  • Review policies and procedures for compliance with Federal contractor regulatory requirements
  • Review employment ads, recruiting source letters, job postings, job descriptions, application forms, employment offer letters, self-identification documents, purchase orders, new hire orientation documents, exit interview forms, I-9 forms and related documents and record keeping processes for compliance with regulatory requirements
  • Prepare outreach letters to be sent to minority and female recruitment and community sources
  • Assist in the investigation of OFCCP and EEOC complaints and preparation of written responses
  • Assist clients with other areas of concern
TRAINING
KAIROS SERVICES, INC. designs, develops and delivers training programs to Human Resources professionals as well as managers and supervisors on a wide range of EEO and Affirmative Action and related topics. Each training program is customized to meet the needs of each company, its industry and the training participants.

Partial Sample Training List:

  • Basic Affirmative Action Concepts (Affirmative Action 101)
  • The OFCCP Regulations: How Can I Avoid the OFCCP Radar Screen
  • THE AAP: Understanding – Analyzing – Taking Action – Getting Results
  • The OFCCP Compliance Process – Methodology & Compliance Reviews
  • Compensation: Analysis and Achieving Pay Parity
  • Record Keeping, Data Collection and Monitoring
  • Impact Ratio Analysis: How Bad Things Can Happen to Good Managers
  • Discrimination and “Back Pay”: What They Are and How to Avoid Them
  • Train-the-Trainer: HR Managers Convince Management to Do the Right Thing
  • Outreach and Recruitment Strategies: Targeting to Increase the Pool
  • The Importance of “Disposition Codes” and Strategically Managing Your Applicant Pool

KAIROS SERVICES, INC. training programs are developed and delivered by Affirmative Action and EEO experienced trainers and are designed to achieve a high level of interaction with participants.

OTHER SERVICES AND PRODUCTS
KAIROS SERVICES, INC. provides a variety of other services to customers that include, but are not limited to, the following:
  • Assistance in Preparation of EEO-1 Reports, VETS-4212 Reports and progress reports
  • Periodic monitoring reports, such as monthly or quarterly Impact Ratio Analyses
  • Compensation analyses
  • Cohort analyses
  • Conciliation services
  • Customized report preparation
  • Matching company job titles to “EEO categories” and census codes
  • Evaluation of employment selection criteria
  • Use of Census Website