On December 13 of last year a number of long-awaited changes to the regulations covering affirmative action plans (AAPs) went into effect.

All companies with more than 50 employees and $50,000 of federal contracts or subcontracts are subject to these regulations. Companies with valid AAPs may use them until they expire.

One of the biggest changes is the mandated use of the Equal Opportunity (EO) survey. Employers will be required to file the EO survey, which is similar to the EEO-1 but contains detailed compensation information, on a biannual basis.

The 8-factor analysis is being condensed to two. This analysis forms the basis of the Availability Analysis, from which good-faith goals are created. The two new factors are combinations of internal and external availability. Detailed justifications are now required for these factors.

The government is now allowing the preparation of a graphical “organizational profile” in place of the workforce analysis. Companies may choose which method to use.