Affirmative Action Resource Manual

The 2016 Affirmative Action Resource Manual supports the agenda of NELI's one-day Affirmative Action Workshop, held in October 2016.

This Manual is prepared especially for federal contractors and subcontractors, as well as those employers which are not contractors but which wish to develop voluntary Affirmative Action Plans using federal contractor requirements under Executive Order 11246 as a model. Experienced Affirmative Action Program writers, planners and managers will also find this Manual useful to update or upgrade existing Affirmative Action Programs and to identify new approaches to affirmative action planning. The chapter containing a Model Affirmative Action Program has been revised and updated to provide a boiler-plate AAP which conforms with all current requirements from the Office of Federal Contract Compliance Programs (OFCCP).

We wish to thank John C. Fox, Esq. with Fox, Wang & Morgan, P.C., editor of this Manual, for his diligent work. Reproduction of materials contained in this Manual, in whole or in part, is permitted with prior authorization of the copyright holder. NELI's companion Affirmative Action Workbook will also be helpful to those interested in expanding their background in Affirmative Action and related topics.


  • History of the Executive Order Program -- Who is covered, defining a contractor and an establishment, standardized Affirmative Action Formats (SAAF's), what is an AAP, and the basis for setting goals.
  • Affirmative Action Plans for Minorities and Women: A Step-by-Step Guide -- The highlight of this Manual is this step-by-step guide to writing an AAP under Executive Order 11246 according to OFCCP's regulatory requirements, divided into three parts -- the narrative, a "model" AAP, and "model" AAP forms to assist with data collection, analysis and display. Supplement Included: "Implementation of the Protected Veterans and Individuals with Disabilities Regulations" by Joan Moore, The Arbor Consulting Group.
  • Miscellaneous Documents re: Affirmative Action Compliance -- Beyond the AAP -- Other actions contractors must undertake, should availability analyses be "time weighted," parent corporation responsibility for subsidiaries, single-entity analysis, Medicare is a "grant" and does not subject a hospital to the jurisdiction of OFCCP, and flood insurance is a "grant."
  • OFCCP Audit Processes, Remedies and Sanctions -- OFCCP sources of program and investigations authority, remedies and sanctions in a nutshell, current OFCCP compliance evaluation documents, OFCCP audit checklist, OFCCP enforcement remedies, sanctions and debarment authority.
  • Implementation of the Protected Veterans and Individuals with Disabilities Regulation -- What must be implemented and when, practical implementation forms and processes.
  • Instructive Power Points for this Manual -- Background to the AAP (OFCCP's sources of authority, coverage, AAP architecture and design issues, what is an establishment, parent/subsidiary authority); Affirmative Action Program Workbook (narrative, organizational profile, job groups, availability, utilization, goals and good faith efforts); OFCCP's Remedies and Sanctions; Discrimination Law OFCCP Applies (disparate treatment, individual and class-type, disparate impact).

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