Oracle HRMS: Do You Have an Affirmative Action Plan?

By Leigh-Anne McDonald, PMP

Overview

This article is an overview discussing the techniques needed to implement and maintain a successful affirmative action plan, and the types of reports your company is responsible for submitting to meet government regulations in the United States.

Introduction

Government entities are ever increasingly becoming watchdogs scrutinizing a company’s fair employment practices including compensation.  The impact to organizations conducting business with the US government that are not compliant multiplies as more attention is paid to hiring, promotion, and termination decisions.

Promoting workplace diversity in parallel with maintaining compliance is a tough balancing act.  Not only do companies contend with substantial penalties and a zero tolerance policy for errors, they risk losing their government awarded contracts and all too often experience high operating costs to meet record-keeping requirements. And unfortunately, organizations that do not track and report hiring practices are caught in a loop because they lack the ability to see if discrimination is occurring.

Despite the risks and potential high costs to an organization, many do not file annual AAP, EEO, and VETS-100 reports because they believe they are not required to do so, or do not know how to extract the information from their Oracle system.

The Oracle HRMS suite (core and self-service applications) provides the means to capture critical data, organize and maintain the information needed for government mandated HR reporting, and produce the required EEO, AAP, and VETS-100 annual reports in a variety of media.  This article is an introduction to fair hiring practices, reporting regulations, and requirements, and it provides advanced overviews for configuring Oracle 11.5.10 HRMS (using job management) to input and track data, and effortlessly produce timely, compliant reports for your organization.

AAP Overview

The US government’s OFCCP (Office of Federal Contract Compliance Programs) - Department of Labor requires companies to file an annual report detailing hiring practices. If your company is a Federal Contractor or Subcontractor with employee headcount of 50 or more, and you have been awarded a $50,000 contract (as either a Prime or a Subcontractor), you are required to have an Affirmative Action Plan (AAP) and report annually.  -  U.S. Department of Labor, Office of the Assistant Secretary for Policy

Normally Federal contractors and sub-contractors report AAP information on a calendar basis because it aligns with other year-end activities that also audit and update employee data, such as:

q  The Payroll Department’s preparation to distribute employee W-2 statements

q  Statistical analysis that may result in changes to the chart of accounts, job titles, or the organization’s supervisor hierarchy

q  Operational analysis of moneys distributed to employees as bonus, commission, or paid vacation

Government data requirements for affirmative action plan reporting are:

Recommendations

q  Once all information is gathered and validated, use Oracle Web ADI for HRMS to upload employee data to the HRMS tables. 

q  Implement Oracle iRecruitment to track and house applicant data. Remember applicant data must be kept for a minimum of two years.

q  Conduct an internal audit. Better to identify omissions and duplicates now than be at the mercies of a mandated external audit that will require more of your organization’s valuable time and resources.

AAP Report Types

Oracle 11.5.10 HRMS provides two concurrent programs to meet AAP reporting requirements: AAP – Job Group Analysis Report and AAP – Workforce Analysis Report.

EEO-1 Overview

Under Title VII of the Civil Rights Act of 1964 (as amended by the Equal Employment Opportunity Act of 1972), US employers are required to maintain and report information on an annual basis regarding race and sex of the employees within their companies.  The reports are submitted annually to the Joint Reporting Committee no later than September 30.  -  U.S. Department of Labor, Office of the Assistant Secretary for Policy

Some organizations are not required to file an EEO-1, the most common report.  Exempt organizations include:

q  Native Indian tribes

q  Higher Education Institutions

q  Primary and Secondary school systems

q  Tax-exempt private membership clubs (labor organizations excluded)

It is important to note Kindergarten through Grade 12 school systems and districts are required to file an EEO-5 report, which is a consolidated report for the entire system.  And some state and local governments require the EEO-4 report, which provides employee information to meet federal agencies legal requirements.

Your organization must file an EEO-1 report if any of the following is true:

q  Your organization is a private employer with 100 employees or more.

q  Your organization is a Federal contractor (private employer) with 50 employees or more,

and is one or more of:

q  a prime contractor awarded a contract of $50,000.00 or more;

q  a depository of Government funds in any amount;

q  a financial institution that is an issuing and paying agent for U.S. Savings Bonds and Notes.

(Note: Oracle HRMS – The Fundamentals (US) has summarized EEO reporting criteria in more detail, and is one of the sources that I used for this overview.)

EEO-1 Report Types

The type of report to file depends on the number of locations an organization has and there are two categories:  single-establishment report and multi-establishment report.

A single-establishment is an employer with one business location. They are required to file one copy of SF100 (single form 100), which is represented as the concurrent program EEO Individual Establishment Report in Oracle 11.5.10 HRMS.

A multi-establishment is an employer with multiple business locations.  They are required to file multiple copies of SF100 with two constraints: each employee is only counted once and the reports contain no duplicates.  A multi-establishment report is broken down into three parts: establishment, headquarters, and consolidated.

The establishment report is required for each location employing 50 or more employees.  The establishment report is represented in Oracle 11.5.10 as the concurrent program EEO Individual Establishment Report.

The headquarters report covers employees working at the organization’s headquarters location and is required if the employees are not included on any other reports.  If the organization’s headquarters employs more than 50 people, the establishment report is used and the headquarters report is not required.  If the organization’s headquarters employs less than 50 people, the headquarters report is required and is represented in Oracle 11.5.10 HRMS as the concurrent program EEO Headquarter Report.

The consolidated report includes all employees by gender, ethnic origin, and job category. The consolidated report is required regardless of employee headcount at each location. This report will contain a count of how many EEO-1 reports are being submitted.  The establishment and headquarter reports’ total employee count must equal the consolidated report’s employee total. 

Vets 100 Overview

“The Vietnam Era Veterans' Rehabilitation Act of 1974” requires all institutions with federal contracts of $10,000 or more for procurement of personal property and nonpersonal services (including construction) to take affirmative action to employ and to advance in employment qualified disabled veterans and veterans of the Vietnam Era, which is defined as the period August 5, 1964, through May 7, 1975. -  U.S. Department of Labor, Office of the Assistant Secretary for Policy

The US Department of Labor requires some organizations to file an annual report that identifies that fair hiring and compensation practices are being upheld for Vietnam-era veterans, disabled veterans, and other war veterans.  The report, the Federal Contractor Veterans Employment Report (VETS-100) covers a one-year period and whom files it is determine by legislative regulations.

VETS-100 Report Types

Similar to EEO-1, VETS-100 reports are filed for single-establishment and multi-establishment employers.

A single-establishment is an employer with one business location. They are required to file the VETS-100 report, which is represented as the concurrent program Veterans Employment Report in Oracle 11.5.10 HRMS.

A multi-establishment is an employer with multiple business locations.  A multi-establishment report is broken down by establishment, headquarters, and consolidated.

The establishment report is required for each location employing 50 or more employees.  The establishment report is represented in Oracle 11.5.10 as the concurrent program Veterans Employment Report.

The headquarters report covers employees based in the organization’s headquarters office and is represented in Oracle 11.5.10 HRMS as the concurrent program VETS-100 Veterans Employment Report.

The Oracle 11.5.10 HRMS concurrent program the Consolidated Veterans Employment Report provides detail by state and includes information about an organization’s hiring locations

with fewer than 50 employees, and it too is a required report.

Similarly, the Oracle 11.5.10 HRMS concurrent program Establishment Employment Listing provides detail by establishment in each state and includes information about an organization's hiring locations with fewer than 50 employees.  It is a required report.

VETS-100 Report Submission

Oracle 11.5.10 supports a number of report submission methods that are recognized by the US government as acceptable means of communication.

On-Line

Single-establishment organizations typically use the VETS-100 on-line service.

Diskette

Organizations with 10 or more sites that typically submit reports from one central location save data electronically to diskettes.

Hard Copy

Organizations with 9 or fewer locations typically use this method.

Note:           The Establishment Employment Listing is always submitted as hard copy and/or attached to an email with the Consolidated Veterans Employment Report.

As with any implementation or configuration of an Oracle product, it is strongly recommended you use the implementation and user guides provided and follow the steps in the order listed.  What follows are two tables.  The first lists Oracle’s recommended steps for configuring Oracle 11.5.10 to enable your organization to enter data to meet the requirements of your Affirmative Action Plan (AAP) and, in turn, extract data in report format to meet federal government requirements.  The second table lists Oracle’s recommended steps for configuring your Oracle 11.5.10 environment to enable your organization to extract data to meet federal mandates for Equal Employment Opportunity (EEO) and VETS-100 (Veterans Employment) reporting.

Oracle 11.5.10 Configuration Requirements for AAP Reporting

AAP reporting groups employees by the affirmative action plans covering them. To meet this directive, organizations are classified as an AAP Organization, representing unique affirmative action plans.

Oracle 11.5.10 Configuration Requirements for EEO and VETS-100 Reporting

Note 1: Organization Classifications

1.       Add and Enable Corporate Headquarters.

2.       Add and Enable Business Group and complete data entry for EEO Report Details, Reporting Categories, and Reporting Statuses.

Note:             In EEO Report Details, select EEO1 from Report Selection LOV.

3.       Add and Enable GRE / Legal Entity and complete data entry for EEO-1 Filing.

4.       Add and Enable Parent Entity and complete data entry for EEO-1 Parent Entity Data and EEO1 / VETS Establishment Data.

5.       Add and Enable Reporting Establishment and complete data entry for Establishment EEO-1 Filing.

Note:            Do not add Reporting Establishment to every one of your organizations, as your reports will return no data. Associate Reporting Establishment only with the top organization that your HR Organizations will be reporting under.

6.       Add and Enable HR Organization.

Note:            EEO and VETS reporting requires that organizations with employees assigned to them have an Organization Classification HR Organization.

Single-Establishment Hierarchy

1. Determine the top organization of the hierarchy.

q  It should be a GRE and a Reporting Establishment.

q  It may be a Business Group / GRE.

2.       Build the hierarchy.

q  Place all HR Organizations in the GRE or Business Group / GRE at the second and lower levels under the top organization.

Multi-Establishment Hierarchy

1. Determine the top organization of the hierarchy.

q  It may be a GRE or Business Group / GRE.

q  It should not be a Reporting Establishment or HR Organization.

q  It should not have the classification Corporate Headquarters.

2. Build the hierarchy.

q  Place the applicable establishments and HR Organizations subordinate to the establishments at lower levels.

Headquarters Hierarchy

1. The top organization is classified as Corporate Headquarters.

q  It should also have the classifications GRE and Reporting Establishment.

2.       Build the hierarchy.

q  Place all HR Organizations at the second and lower levels under the top organization.

Conclusion

I have covered all the tasks necessary in setting up your Oracle environment for tracking and reporting on AAP, EEO, and VETS-100 data.  It is assumed that you have Oracle HRMS fully installed and are using it in your day-to-day business operations for employee management.  As noted in the two set-up tables, it is critical that the tasks be performed in the order listed, as many are pre-requisites.  When defining your affirmative action plan and performing the set-up tasks, it is important to use date tracking functionality to ensure all eligible employee data is captured.  And finally, remember the benefits of organizing your employee data as it touches many aspects of your business from year-end analysis to W-2 statements to PTO accruals. 

Sources

The information in this document was compiled from Section 709(c) Title VII of the Civil Rights Act and Using Oracle HRMS - The Fundamentals (US).

This white paper originally was published in ORAtips.