AďŹƒrmative Action Program Planning Smart Software, Tools, and AAP Services
Your Path to Compliance
A Business Partner You Can Trust . . .
Our Company Founded in 1988, Gerstco provides expert consulting services to U.S. federal contractors who must prepare and maintain Equal Employment Opportunity (EEO) and Aﬃrmation Action Program (AAP) plans. Our mission is to bring strategic, cost-eﬀective program solutions to clients in their eﬀorts to meet the challenge of employing and retaining a dynamic workforce, while maintaining regulatory compliance. Women’s Business Enterprise National Certification
Affirmative Action Planning Expertise
Gerstco, Inc. is certified as a women’s business enterprise through the Women’s Business Enterprise National Council (WBENC), the nation’s largest third party certifier of businesses owned and operated by women. We recognize the commitment to supplier diversity that is embraced by corporations and government agencies today, and we can add diversity to your supply chain.
Gerstco employs experienced, seasoned professionals who bring instant credibility to government compliance situations. Each Gerstco staff member has extensive education and training in affirmative action program development, compliance, and strategic workforce planning.
Nationwide Service We serve a diverse set of U.S.-Wide Industries: Biotechnology, Communications, Computers and Related Devices, Defense, Drugs and Pharmaceuticals, e-Commerce, Education, Electronic Instrumentation, Engineering Services, Environmental Consulting, Finance, Food, Health and Medical Services, Internet Services, and Environmental Services, Medical Device Manufacturing, Semiconductors, Software Publishing, Transportation, and Waste Management, as examples.
Working with clients over time, we can recommend practical solutions and best practices to long-standing workforce issues. Gerstco’s staff keeps up-to-date on all aspects of regulatory requirements and contractor obligations, including understanding when emerging regulatory issues become contractor requirements. We strive for excellent service results. And, while we can state our positive intentions in listening to customers, nothing speaks louder than customer recommendations. Please request references.
Innovation We continuously improve our products and services. In 2010, Gerstco introduced AAPCalendarBase, the first online industry application for scheduling Affirmative Action Planning and related activities in support of Program implementation.
Automation & Technology Gerstco AAP software products are designed to ensure data accuracy, handle repetitive tasks systemmatically, and decrease the time needed to prepare technical Affirmative Action Plans. Since 2001, our software products have fulfilled these goals.
AAP Software Systems Gerstco uses AAPBase, a proprietary software for developing Affirmative Action Plans. Two other specialized software applications have been designed and are used to support the AAP Program: (1) CENSBase, software, which interacts with AAPBase in developing the 2-Factor Availability’ for minorities and women; and (2) COMPBase, software, for performing compensation analysis. Clients include large, medium and small U.S. federal contractors, with Affirmative Action Plans ranging in size from single to multi-site, multi-state Plans. Some clients require Affirmative Action Plans structured by organization, business unit, or product line, rather than by geographic location. Our services include experience in all these AAP areas.
All software is trademarked and licensed to Gerstco, Inc. Using proprietary software ensures no (hidden) use or royalty fees. Gerstco software methodologies, formats, and reports are proven documents for management information and government reporting. We have licensed our AAP software applications to federal contractors since 2002.
Providing more than twenty years of service to Federal Contractors
Professional Services You Can Count On . . .
Aﬃrmative Action Program Development Gerstco designs and develops Affirmative Action Plans that meet the specific needs of contractors while maintaining contract compliance. We work in consultation with clients to ensure their plans accurately reflect their organization structures and practices. Our AAP design process involves mutual decision-making: understanding a contractor’s reporting structure, identifying Corporate employees and employees reporting across geographical AAP sites, forming AAP job groups and identifying recruitment areas, determining the ‘availability’ of women and minorities, selecting appropriate AAP goal methodologies, and preparing appropriate compensation analyses for Desk-Audits.
Specialized Affirmative Action Plans Gerstco prepares specialized Functional Affirmative Action Plans (FAAPs) or traditional location-based AAPs. When requested, we will provide guidance to contractors in working with programs enforced by the Office of Federal Contract Compliance Programs (OFCCP).
AAP Development To meet business objectives and achieve contract compliance in an agreed-upon time frame, our AAP development process is segmented into four phases: 1. project planning, 2. data gathering, 3. AAP development and 4. AAP publication.
Year-Round Support We encourage clients to keep in touch with us during their AAP year. Our business objective is to respond on the same business day, or as soon as practical.
EEO-1 Reporting & Filing Service
Technically-Compliant Affirmative Action Plans (AAPs) Gerstco AAPs include required program narratives, policies, reports, analysis, and procedures for Executive Order 11246, the Rehabilitation Act of 1973, and the Vietnam Era Veteran’s Readjustment and Assistance Act of 1974. AAPs are considered ‘compliance-ready’ when completed.
AAP Supporting Documentation This separate AAP document supports OFCCP compliance by providing detailed hires, promotions, terminations, and applicant listings. In addition, Impact Ratio Analysis results, employee listings, Compliance Flags reporting*, and other client-requested documentation, can be included.
*Compliance Flags Reporting In advance of a Compliance Evaluation, Gerstco Compliance Flags reporting provides a unique analysis for clients under review. Compliance ‘flags’ can indicate problem areas in recordkeeping or other AAP areas. In this way, Gerstco clients will be ahead of the curve in compliance-readiness.
Electronic AAP Format (eAAP®) Gerstco’s ‘electronic’ AAP can be delivered to clients in PDF format, on a CD, or down-loaded from our secure web site. Benefits to receiving an eAAP, include: a more secure transmission and efficient distribution to other office locations.
The US Equal Employment Opportunity Commission (EEOC) conducts its annual EEO-1 Survey for private sector employers during the period July 1 - September 30, each year. This is not a voluntary survey but one required by the Civil Rights Act of 1964. Gerstco can prepare and submit Company EEO-1 forms to EEOC’s Joint Reporting Committee electronically, in hard copy or via the EEO-1 online system, on an annual basis, as required.
VETS Reporting & Filing Service
AAP Client Orientation
The U.S. Department of Labor (DOL) Veterans’ Employment and Training Service (VETS) collects and compiles data through the Federal Contractor Program Veterans’ Employment Report during the period August 1 - September 30 each year. Gerstco can prepare and submit VETS-100 and VETS-100A forms to DOL’s Veterans’ Employment and Training Services (VETS) in hard copy or via the VETS online system.
Gerstco will deliver and communicate Affirmative Action Plans via web conferencing or at client locations. These meetings can provide an understanding of workforce issues and demographic changes. Senior Consultants provide: (1) a detailed orientation to the Plan; (2) an assessment of the AAP ‘compliance readiness’; and (3) suggested remedies and strategies in implementing the AAP.
Gerstco consultants provide customized presentations for Executives, Managers and HR personnel. These presentations include: company performance to goals, workforce and industry comparisons, performance to AAP Goals, and specialized organizational views.
Responsive Affirmative Action Program Development
Responsive Compliance Management . . .
Compliance Evaluation Services Compliance Evaluations by the U.S. Department of Labor’s Oﬃce of Federal Contract Compliance Programs (OFCCP) can be time-consuming to those responsible for aﬃrmative action planning. To support clients during their audits, Gerstco Senior Compliance Specialists maintain up-to-date knowledge regarding OFCCP enforcement practices and deliver a unique set of targeted services. The Desk Audit When contractors receive a ‘Notice of Review’, the AAP development process is accelerated for items that have been requested, including; the Affirmative Action Plan, compensation information and mid-year updates. Special Compliance Management Briefings are scheduled with Human Resources and Managers to prepare them for the compliance process and to provide an in-depth analysis of the organization’s AAP performance. The On-site Review Gerstco provides a ‘pre-audit’ service to assess a contractor’s state of readiness for the On-site review. OFCCP will often notify contractors that they intend to conduct an On-site Review following a Desk Audit. After the pre-audit is concluded by Gerstco, site management will be briefed. To deal with information requests and other compliance matters, Gerstco can also place a Senior Compliance Specialist on-site during the audit process.
Sometimes OFCCP requests a specialized audit such as a Job Site review, Department review, or Position review. As requested, Gerstco will provide consulting and document support for these specialized audits.
Compensation Analysis Services for the Compliance Evaluation Increased scrutiny by the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) involves efforts to determine whether discrimination exists in contractor pay practices concerning females and minorities as compared to males and non-minorities. OFCCP’s Compliance Evaluation includes a request for compensation information, submitted in summary format. Gerstco can provide the appropriate summary information, as required.
Corporate Management Review A Corporate Management Review (CMR), by OFCCP, will audit the Headquarters locations of multi-establishment firms. To prepare for this specialized audit, our Compliance Specialists will prepare the requested documents, brief the management team and review and analyze all information pertaining to the audit with Human Resources, Legal, and Executive managers. Following the CMR document submission, Gerstco assists contractors in preparation for the CMR on-site review. In many ways, a Corporate Management Review includes all the attributes of a regular Compliance Evaluation. The emphasis of a CMR, however, is to evaluate how minorities, women, veterans and individuals with handicaps, move into management and other key positions and ensure that artificial barriers do not impede advancement. For discussion and analysis, Gerstco will prepare customized organizational reviews and presentations for major organizations.
Focused Compliance Evaluations
When a Desk Audit is scheduled after the AAP effective date, mid-year AAP reporting may be required to comply with OFCCP’s Itemized Listing request for information. If this occurs, Gerstco will prepare personnel activity data (such as hires, promotions, terminations and applicants) for submission to the OFCCP and develop the following additional reports and analyses: • Summary and detail activity reports for the mid-year period, • Adverse impact analysis of personnel activities for the update period, and • A Performance to Goals analysis for the update period.
A focused review is a Comprehensive Evaluation by the Department of Labor’s Office of Federal Contract Compliance Programs to review certain departments, job sites, locations or specialized situations in a contractor’s workforce. Upon request, Gerstco will provide consulting and document support for specialized reviews.
Gerstco AAPs reports and methodologies have been acceptable in all government audits
Compensation Analysis and Contractor Self-Evaluation . . .
Compensation Services Gerstco oﬀers a spectrum of compensation services to assist federal contractors in evaluating and monitoring the results of their pay practices. Compliance Evaluation Pay Submission OFCCP’s scheduling letter includes a request for employee compensation at the Desk Audit stage. Pay must be submitted in summary format. Contractors have options in providing salary information by job group, range, rate, or grade, showing total workforce demographics of race, gender and ethnicity. Gerstco can assist contractors in preparing and submitting confidential data and results in the most appropriate manner.
Annualized Compensation Report - An annualized compensation analysis is a required part of a Desk Audit submittal. This type of report can be presented by pay grade,job title, or job group, or other logical grouping.
When OFCCP’s pay request goes beyond the Desk Audit, a more detailed salary analysis will be needed. At this point, Gerstco can provide more specific analyses: A cohort analysis of discrete jobs and small employee groups; Regression analysis using OFCCP factors; and Multiple regression analysis using factors considered to influence pay based
on stated pay policies. Types of analyses Gerstco uses to support the Desk Audit include: A Means Analysis - A Mean Statistical Significance Analysis that compares annual employee compensation by race and gender at a specific AAP location. A Median Analysis - A Median Statistical Significance Analysis compares the compensation of females and minorities to males and non-minorities at the mid-point of a Pay Grade, Job Title or Job Group. Pay Discrepancy by Job Title Analysis - This report examines each Job Title used in an AAP and displays titles where there are pay discrepancies between females and males and minorities and non-minorities. Where there are differences in annual pay, the actual pay difference and the percentage differences are shown. A high percentage pay difference can indicate the need to perform a more detailed analyses. Pay Discrepancy Details - This report identifies specific employees and their attributes. Cohort Analysis - Cohort Analysis is an individualized look at pay decisions for employees in similar positions. Gerstco’s staff assists contractors in identifying legitimate areas for further investigation. Often, performing multiple regression can eliminate many areas of salary concern. However, when statistical analyses fail to account for all pay disparities or, a population does not lend itself to complex mathematical formulas, it may be necessary to review employee information on a one-to-one basis (often referred to “cohorts”).
Self-Evaluation of Pay Practices - Long before notification of an Audit, Gerstco advises clients on their pay practices. Although your organization may not be under review, a self-evaluation may determine whether pay practices are communicated and administered fairly. Multiple Regression Analysis - When the results of previous salary analyses indicate the need for further review, Gerstco’s staff can employ more complex analysis methods such as regression and multiple regression analysis. These mathematical methodologies evaluate the degree to which employee attributes of age, race and/ or gender, are correlated with pay. The results are presented in scatter graphs and numerical charts.
Tools, methods & tests available to ensure non-discrimination in pay practices
Professional Software for AAP Planning . . .
AAPBase is a comprehensive affirmative action program development software combining all regulatory requirements into a single application. With this ‘suite’ of software tools, AAPBase maintains historical data and generates single, locationbased, multi-site reporting along with Functional AAPs.
COMPBase is Gerstco’s proprietary and comprehensive compensation analysis system. A Windows-based software application, COMPBase has been in regular use for OFCCP compliance, company self-evaluation, and litigation support since 2004. The system integrates a full statistical package (Statistica) and an ad hoc reporting tool (Stonefield Query), for non-standard reporting.
The software is designed featuring more than 250 standard reports. The following features are part of AAPBase: •
Compliance Reporting – AAPBase efficiently produces all required reports
and analyses for government-compliant affirmative action program reporting, including: an accurate Workforce and Job Group Analysis, a 2-Factor Availability Analysis, an Incumbency to Availability Analysis and the establishment of AAP goals, as needed. A special set of ‘Compliance Flag’ reports reside within AAPBase that can be quickly produced to alert potential ‘problem areas’ when preparing for a Compliance Evaluation. Non-discrimination Testing – AAPBase analyzes hiring, promotion, and termination selections using standard Impact Ratio Analysis, Statistical Significance and other mathematical formula. The software will identify areas of potential impact for total minorities, each minority group, women, and individuals age 40 and over. Applicants for Employment – Applicant monitoring and analysis has been designed into AAPBase to record, track and analyze recruitment efforts and hiring practices by federal contractors. Pay Analysis – AAPBase’s pay analysis option quickly analyzes salary information for compliance reporting and initial non-discrimination testing. Reports include: Cohort Analysis, Mean and Median analysis, OFCCP statistical significance detail analysis, Pay Discrepancy analysis, and Paragraph 11 submitted in OFCCP’s Scheduling Letter. Internal Auditing – AAPBase provides detailed, in-depth reporting at all organizational levels for diversity administration, discrimination testing, internal investigation of company practices, and detailed AAP performance results not usually available.
CENSBase 2000 Labor Force Analysis software developed by Gerstco is integrated into AAPBase for purposes of developing ‘availability estimates’ for minorities and women. CENSBase combines geographic information with workforce information to provide special ‘views’ for workforce planning. Gerstco will license CENSBase to government contractors and other firms interested in external labor force statistics.
COMPBase has a single-panel interface for quick access to all its features including: database creation, importing, data searching, data editing, defining groups (similarly situated employees), and running analyses. Imported workforce data may contain up to 254 fields. Any field that might be used to establish employee groups can be imported. “Employee Groups” in COMPBase are defined using a full-featured expression builder to establish conditions under which employees should be considered “similarly situated.” This expression-builder defines comparison groups for analysis.
Gerstco’s newest application is AAPCalendarBase, a secure, web-based software that maintains an organization’s affirmative action program-related events for federal and state programs. The software is available to users wherever there is a connection to the Internet. Software users can access, update, and share calendars from home, while traveling, and anywhere they may be. Primary features in AAPCalendarBase are: • • • • •
Plan and document program activities Schedule automated email reminders Share calendars with others View calendars in familiar formats Export to Outlook and other personal calendar programs
AAPCalendarBase provides an interview process to guide calendar users through affirmative action program activity planning. The interview is organized by affirmative action program area (Minorities and Women, Individuals with Disabilities, and Veterans) and other AAP requirements. Each section of the interview presents easy to answer questions related to scheduling events for compliance with current federal regulations. As questions are answered that indicate critical details about the organization’s program, AAPCalendarBase builds a detailed calendar containing all the selected events on the appropriate times and dates.
Gerstco licenses comprehensive AAP Software
An Educational Partner You Can Rely On . . .
Training & Education Training and Education are major objectives in Gerstco’s Core Values. We provide EEO/AAP training to Human Resources professionals, Managers and Recruiters who have the responsibility to assist with the implementation of their organization’s Affirmative Action Plans. Our events and training take many forms, including public workshops, in-house and customized training sessions.
Webinars Webinar agendas are topical in nature, dealing with current compliance issues, enforcement strategies, regulatory focus and government practices for federal contractors. These focused sessions have held value over the years for those experienced in EEO AAP, and for those who desire to remain current on AAP practices.
Gerstco offers a variety of workshops to support basic and continuing education needs of AAP Professionals. Individuals new to the EEO/AAP field find our Workshops perfect for understanding AAP basic concepts, legal principles and best practices needed to implement Affirmative Action Programs. Workshops are designed for federal contractors who may not have prior experience or training in EEO policy or Affirmative Action Programs (AAP). The introductory workshop “Building a Compliant Affirmative Action Program”, is a two-day hands-on workshop designed to review the basic Affirmative Action requirements for federal contractors, address company policies necessary for compliance and provide attendees with experience in implementing technically-compliant Affirmative Action Programs. Workshops are held in Silicon Valley (Cupertino, California) and at customer facilities.
Continuing Education Courses at Gerstco Examples of individual classes that can address specific needs: • The Legal Framework for Affirmative Action Programs; • Building Compliant Affirmative Action Program Narratives; • Examining Statistical Elements of an Affirmative Action Program; • Recordkeeping Requirements for the AAP; • Internet Applicant Recordkeeping Procedures; • OFCCP and Affirmative Action Program Compliance Today; • OFCCP’s Top Ten Issues in AAP Compliance; • Constructing An Affirmative Action Planning Calendar; • Auditing your Affirmative Action Plan; • Compensation Analysis; • Understanding Compliance Evaluation Processes; • Federal Contractor Management Briefing; • Constructing Your Own Affirmative Action Program; and • Implementation of Your Company’s Affirmative Action Program
Custom Training We value continuing education and believe that individuals are more effective, interested and successful when they understand Equal Opportunity principles and Affirmative Action obligations. Gerstco offers customized, practical EEO and AAP training for Managers, Human resources Professionals, and others involved in implementing AA Programs.
Management Training Gerstco provides specialized training for managers in EEO and Affirmative Action Program (AAP) obligations. Briefings begin with an overview of equal employment opportunity. Managers discuss affirmative concepts that may apply to their responsibility areas, such as: interviewing and selecting employees, career counseling, outreach, and the achievement of AAP goals. Management Briefings are a convenient forum to communicate company policies, practices, and recordkeeping requirements and build support for the overall Affirmative Action Program.
Customized Briefings Gerstco offers customized, in-house briefings and management training on EEO matters, Harassment prevention, AAP implementation and compliance, and Interview and Selection Practices. These in-house sessions are company-specific and can be confidential.
Management Briefing Topics • Understanding the firms’s AAP obligations,
• Attracting and retaining the best talent regardless of gender, race, ethnicity, age, disability or veteran status, and • Affirmative Action Programs beyond legal compliance. The following is a typical agenda for Management Briefings: • The Legal Framework of Affirmative Action Programs, • Discussion of Employee and Management Roles and Responsibilities, and • A high-level look at the Affirmative Action Program Planning Process.
Recruiter Training Current OFCCP Internet Applicants regulations require federal contractors and subcontractors to gather and maintain accurate applicant information on all positions filled during an AAP year. Gerstco has developed a training session for Recruiters to review their obligations on applicant tracking and monitoring and understand how AAP requirements may apply to their recruitment practices. This has been an effective forum for Recruiters to discuss open issues and to propose refinements to the organization’s applicant tracking process.
Continuing education is a core value at Gerstco 7
We Keep You Informed . . . AAPNews
Gerstco publishes AAPNews that covers a wide variety of information on policies and practices related to OFCCP and EEOC. Our Newsletter offers analyses of regulatory requirements, best practices, and resources for developing and supporting Affirmative Action Programs. At publication, the Newsletter is posted to our website, www.gerstco.com. Clients and mail-list subscribers are emailed notification of topics and a web link for downloading in PDF format.
Each contractor’s Affirmative Action Program is different and may require different strategies. Gerstco’s website will provide a road map to get you started in implementing your Affirmative Action Plan requirements. The web-site road map provides a ‘big picture’ view of AAP requirements and information regarding Department of Labor’s Office of Federal Contract Compliance (OFCCP) enforcement practices. The road map also provides a detailed look at all the contents in an Affirmative Action Program.
Find News and Resources
Gerstco sends clients and mailing list subscribers free Alert Bulletins via email regarding filing deadlines and changes to DOL/OFCCP policies and practices.
We are committed to keep clients informed of EEO and Affirmative Action requirements. Our email alert system and website are effective ways to build knowledge regarding Affirmative Action Planning. Samples of information and resources Gerstco provides: • AAP News articles by topic (current and archived copies) • Links to Government websites (DOL, OFCCP, EEOC) • Links to relevant Government published forms • Links to government documents • Glossary of AAP terms • Library with AAP-related documents
To join our mailing list please register online at www.gerstco.com
Customer Connection – A Secure Website Page for Clients Client Document Exchange During the AAP development process, clients need to transmit data files to Gerstco. Using email, with file attachments, is quick and convenient, but it may not provide adequate security. We recommend using the Gerstco Extranet which maintains data security during transmission. Using our customer connection and Extranet allows clients to securely receive AAP reports and completed AAP documents.
AAP CalendarBase . . . a 24/7 Calendar
Gerstco offers a new web-based service dedicated to scheduling and documenting Affirmative Action Program Efforts. AAPCalendarBase was designed to assist federal contractors with documenting, reporting, and communicating all aspects of their AAP program. The software is a secure, web-based application that is always open and available. AAPCalendarBase users can use and share calendar information from home, at the office or while traveling.
Gerstco is a nationally certified Woman-owned business
20410 Town Center Lane, Suite 100, Cupertino, CA 95014 Telephone: 800-700-0937 Web: www.gerstco.com