Just as in cooking, an Affirmative Action Program (AAP) is only as good as each of its ingredients. The most important ingredient in a successful AAP is good data. Federal contractors would be wise to spend more time understanding this ingredient before they begin mixing in others.

Simply put, any analyses of a federal contractor’s personnel activities or progress in meeting placement goals is only as good as the initial data that is used to create the analyses. This is particularly true in light of the Office of Federal Contract Compliance Programs’ (OFCCP) practice of “following the numbers” in compliance reviews—an approach which focuses on all statistically significant adverse impact findings, regardless of who the protected group is. All too often, however, federal cont