The simple answer to your question is "No." The personnel activity data should have dates that are attached to the snapshot date. There are multiple reasons for this. The simplest is that it is illogical to have data sets that don't correspond to each other. You're trying to measure outreach activities and potential disparities via your personnel activity data, and you're trying to measure demographic distribution within the current workforce via the snapshot data. There should be a link between what the demographic distribution looks like, the outreach activities that may have produced that distribution, and the possible selection issues preventing your organization from achieving a more equitable distribution. The second reason the personnel activity data should correspond to the snapshot data is that the itemized listing received when an organization undergoes a compliance review requests "Data on your employment activity (applicants, hires, promotions, and terminations) for the immediately preceding AAP year..." (See item 18.) Thus, if you have a January 1, 2017 AAP, the itemized listing is seeking personnel activity information for the period from January 1, 2016 through December 31, 2016. Finally, the third reason the personnel activity data should correspond to the snapshot data is that federal contractors and subcontractors are required to update their affirmative action plans on an annual basis. The Executive Order 11246 regulations require an annual review of personnel activity data, while the regulations regarding protected veterans and individuals with disabilities require an annual analysis of a series of data metrics. One could make an argument that these analyses could cover non-corresponding period (there could be an April 1 snapshot in an AAP with personnel activity data for January 1 through December 31), but there would then be problems with analysis of personnel activity being constantly out of sync with the annual update to the snapshot-related reports such as the organizational profile, the comparison of incumbency to availability, and the disability utilization analysis. The bottom line: you might be able to argue that there is no specific, formal requirement in the regulations that the snapshot data should match the period for the personnel activity data, but OFCCP will have very strong objections to this and you will miss an opportunity to review your data in the same manner in which OFCCP expects to review your data.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.