On page 48 of the July 2013 Federal Contract Compliance Manual (FCCM) the OFCCP describes its methodology for calculating the impact ratio and how the compliance officers (CO) are supposed to use the results of the impact ratio analyses:

  • Although related, a CO must not confuse adverse IRAs with the term “adverse impact.” The Impact Ratio Analysis (IRA) is a method for identifying personnel activity that should be investigated further onsite. The IRA is a ratio between two selection rates, one for minorities or women, and one for others. Generally, if the selection rate for a particular group is less than 80% of the selection rate for the favored group for a particular personnel activity, (e.g., the selection rate for minorities or women is less than 80% the selection rate for non-minorities or men for a particular personnel activity), a CO must [emphasis added] investigate further during the onsite. [FCCM, July 2013, page 48].

Even though the OFCCP in the above description suggests that t