As Federal contractors begin to utilize the 2010 EEO Census File to generate availability data, it provides a good opportunity to remind plan developers to take a look at how they are calculating their availability pools. Contractors need to avoid going on autopilot when it comes to defining their affirmative action plan structure. Things have changed and contractors need to visualize the impact those changes have on their goals and resulting outreach efforts. Plan developers should regularly undergo efforts, at least annually, to ensure that they are creating accurate, meaningful and defensible analyses. This is particularly important at a time when Good Faith Efforts made towards reaching Placement Goals are squarely in the spotlight during OFCCP audits.

Most affirmative action practitioners are now familiar with how OFCCP audits have (seemingly) b