Circa Named a Winner of the Southeast Wisconsin Top Workplace 2023 Award. Read Press Release+
First things first: if by "How do you generally recommend we set up job groupings" you mean "How do we establish job groups for our federal affirmative action plans?", job groupings should be specific to each individual AAP. OFCCP does not conduct compliance reviews by organization; it conducts compliance reviews by "establishment." The Executive Order 11246 affirmative action plan that is prepared for any given establishment should be specific to that establishment. The narrative should reflect what is occuring at that establishment, and statistical structures devised for the AAP should be specific to that establishment. Since job groups are such a foundational tool for developing other statistical reports that are included in AAPs, it is especially important to have job groups that are specific to each establishment. Many organizations want to use EEO-1 categories as their job groups. This is often a very bad idea. It can combine jobs that are very much dissimilar with each other. For example, a company that has lots of engineers and lots of purchasing agents at one facility should probably consider separate job groups for engineers and purchasing agents, regardless of the fact they are both part of EEO-1 category 2. The pay for these jobs is likely different, the duties are very different, and the opportunities for advancement are likely to be different. Similarly, a company that has lots of assembler and lots of welders at one facility should consider separate job groups for these two types of positions, regardless of the fact they may both be part of EEO-1 category 7. The demographics regarding individuals who might enter assembler and welder jobs are so different, and the characteristics of these jobs are typically so different, that they do not belong in one job group. If you HR information system REQUIRES you to assign both an EEO-1 category AND an affirmative action job group to each job title or job code that will then be used across facilities, you should do so with great care. From a strategic standpoint, it is better to have lots of job groups with a smaller number of incumbents than the reverse. OFCCP is much more likely to find statistical disparities and compensation issues for a job group that is extremely large than for a smaller job group with a set of positions that are similar in nature. As for sites with less than 50 people, you are required to find a way to report these individuals on your EEO-1 reports. There are two different ways to report worksites with less than 50 people that you can read about in the instructions for filing the EEO-1 report. You are also required to include employees at sites with less than 50 employee in an affirmative action plan if they are part of an entity covered by OFCCP's regulations. Under OFCCP's regulations, you have a number of choices as to how to include persons at smaller facilities in some affirmative action plan. (See 41 CFR 60-2.1) However, OFCCP's regulations are clear that if an organization is covered by these regulations, EVERY employee must be included in some affirmative action plan. It would be great if I could say "Just put jobs into EEO-1 categories, use those for your job groups, and ignore small facilities." Unfortunately, for both EEOC and for OFCCP purposes, that advice would ensure that you are out of compliance with each agency's mandates.
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.