Gather Necessary Data

Gather Workforce & Employment Activities Data

Though there may be other pieces of data that you will need throughout the process of preparing an AAP in The Complete AAP™ (TCAAP), the two most essential are Workforce Data and Employment Activities Data.

*TCAAP is very much dependent on codes ( i.e. Location Codes, Employee ID’s, Job Codes, etc.) and on dates. If you keep codes consistent among all data and follow date rules for workforce data and employment activities data, then you shouldn’t have issues later down the line.

Workforce Data

What is Workforce Data?

The first piece of data you need to prepare your AAP is a a point-in-time list of your workforce as of the first day of your AAP year; many people like to think of this as a “snapshot.” A workforce snapshot is usually exported from a company’s Human Resources Information System (HRIS) and/or Payroll system, and it should include demographic and additional information for all active employees as of the first day of the AAP year.

For example, if your AAP dates are January 1, 2024 to December 31, 2024 (i.e. a calendar year), then your workforce snapshot should include all active employees as of either December 31, 2023 OR January 1, 2024 *.

If you need more help determining your snapshot date, visit our online AAP Date Calculator and read through the AAP Basics chapter of this manual.

*If your current AAP is on a calendar AAP year, you may use the same snapshot data for the next cycle of EEO-1 and/or VETS-4212 reporting, provided that the snapshot is as of December 31.

Workforce Data Import Template

Download a Workforce Data Import Template

The Complete AAP expects an exact number of columns in an exact order during an import; the column order of a given import file is laid out in a template. Click here to download an empty Workforce Data import template. Check your Downloads folder to find the downloaded workforce_data_template.csv file, and save it in an easily-accessible folder. The goal is to pull a data file from your data system(s),copy columns from that source(s), and paste the columns into the template; alternatively, you may develop a query that pulls data from your system(s) in the template order; however, it is unlikely one data system holds all that you’ll need.

Workforce Data Template Definitions

The Workforce Data Template Definitions list below is a vertical list of the headers in the workforce_data_template.csv. This data helps produce several reports required by OFCCP regulations, directives, or audits, but the term Required in the listing below may refer to either software or regulation requirements. In general, include every field that you are able to gather or develop for each employee. For an example of what a populated and ready-to-import workforce template looks like, click here.

Column	Required?	Description & Why You May Need It	Supporting Regulations
		…………………………………………………………………………………………..	……………………………………
Column A Location Code	Optional	Location Codes are unique codes that distinguish the separate facilities at which employees work. Location codes provide a designation for each Location Name, and help the program report employees in the appropriate AAPs according to regulations. If employees work at locations geographically near or adjacent, provide separate codes for each address. If codes are not in your import file, the software will assign random codes for each unique Location Name upon import; for this reason it is recommended that you develop your own recognizable codes.	41 CFR § 60-2.1 (b)(1); 41 CFR § 60-2.1 (e)
Column B Location Name	Required	Location Names are names of the facilities or addresses at which employees physically work. Location names should represent the actual physical address of the work location of each given employee, and they can represent any identifying feature of the address (e.g. SampleCo West Campus, SampleCo Building A, SampleCo West Elm St., SampleCo Cincinnati OH W. Elm St., SampleCo Cincinnati N. Main St., etc.). Even if you’re planning on preparing FAAPs, use employees’ physical location names; this template list includes further down in column AE a solution for creating FAAP locations. Location names are used in annotations to describe where employees work, and, using supervisor or rollup information, where employees report. For remote employees, the OFCCP has declared that employees’ actual work locations (i.e. city and state of their homes) should be reflected in annotations.	41 CFR § 60-2.1 (b)(1); 41 CFR § 60-2.1 (e)
Column C Employee ID	Optional	Employee ID’s are company-assigned employee identification codes. Employee IDs help identify employees and help ensure that employee records are not duplicated in your data. ID’s appear only in the Employee List and the Employee Level Compensation Data report in your published documents. If IDs are not imported, the software will assign them; for this reason it is recommended that you develop your own recognizable ID’s. Please see Supervisor ID for more on Employee ID’s.	41 CFR 60-2.1 (d)
Column D Employee Name	Required	Employee Names are the names or unique identifiers of employees active in your HRIS/payroll as of your snapshot date. There is no order required of the first, middle, or surnames, but you should ensure that there are no duplicate employees in your file. By default, employee names appear on only the supplement Employee List in your confidential Compensation Analysis, but even then you may suppress names on that list.	41 CFR § 60-2.1 (d)
Column E Race	Required	Races are the EEOC-recognized race/ethnicity designations. Click here for a list of recognized races. Race designations are required to ultimately determine whether your utilization of minorities compares statistically to availability. Race demographic totals appear in several required reports. If an employee has not disclosed his or her race, visual determination is permissible.	41 CFR §§ 60-2.11 (b)(3)(ii), (iiv); 41 CFR § 60-2.11 ©(4); 41 CFR § 60-2.13; 41 CFR § 60-2.14 (b)(1); 41 CFR § 60-2.15; 41 CFR § 60-2.16
Column F Gender	Required	Gender refers to the binary gender designations recognized by the EEOC: male and female. If an employee has not disclosed his or her gender, visual determination is permissible. Gender designations are necessary to ultimately determine whether utilization of women compares statistically to availability. Gender demographic totals appear in several required reports.	41 CFR §§ 60-2.11 (b)(3)(ii), (iiv); 41 CFR § 60-2.11 ©(4); 41 CFR § 60-2.13; 41 CFR § 60-2.14 (b)(1); 41 CFR § 60-2.15; 41 CFR § 60-2.16
Column G Department Code	Optional	A Department is an organizational unit most commonly conveyed in the form of a department or unit of supervision. Department Codes are company-assigned identifiers for organizational units. The software uses Department Codes to develop an Organizational Profile, which is a required report depicting the staffing pattern of an organization. If codes are not in your import file, the software will assign random codes upon import; for this reason it is recommended that you develop your own recognizable codes.	41 CFR §§ 60-2.11 (a), (b), (c )
Column H Department Name	Required	A Department is an organizational unit most commonly conveyed in the form of a department or unit of supervision. Department Names are the name your company assigns to each organizational unit. The software uses Department Names to develop an Organizational Profile, which is a required report depicting the staffing pattern of an organization..	41 CFR §§ 60-2.11 (a), (b), (c )
Column I Job Code	Optional but Recommended	Job Codes are company-assigned identifiers for job titles. Job Codes allow the software program to differentiate between individual jobs more precisely than it can using Job Titles. If codes are not in your import file, the software will assign random codes upon import.	41 CFR § 60-2.11 (b)(3)(ii); 41 CFR § 60-2.11 (c ); 41 CFR §§ 60-2.12 (b), (c ); 41 CFR § 2.14(g); 41 CFR § 60-2.17(b)(1)
Column J Job Title	Required	Job Titles are company-assigned titles that describes the work that employees perform. Job Titles allow the reader to easily identify the type of work employees engage in, and allow the software user to assign specific job census codes that provide availability of women and minorities for goal-setting purposes. By regulation, job titles must appear in the Organizational Profile, Workforce Analysis, and Job Group Analysis. It is wise to use more specific titles than broad, general titles in affirmative action to avoid the possibility of statistical disparity in various reports.	41 CFR § 60-2.11 (b)(3)(ii); 41 CFR § 60-2.11 (c ); 41 CFR §§ 60-2.12 (b), (c ); 41 CFR § 2.14(g); C41 FR § 60-2.17(b)(1)
Column K EEO Code	Required	EEO Codes are job categories determined by the EEOC. Click here for a listing and definitions of the EEO-1 categories. EEO codes are used in affirmative action as the basis for forming Job Groups. The Complete AAP uses EEO Codes to assign job census codes.	41 CFR § 60-2.12(e)
Column L (Job) Census Code 1	Optional	Census Codes are codes that are assigned to each unique job, and that carry availability of female and minority demographics in selected geographic census areas for the job described. Census codes may be assigned in your file and imported, or they can be assigned in TCAAP after the workforce is imported.	41 CFR § 60-2.14(c )(1); 41 CFR § 60-2.14(d)
Column M (Job) Census Code 2	Optional	Import a second census code if you wish to further describe jobs.	41 CFR § 60-2.14(c )(1); 41 CFR § 60-2.14(d)
Column N (Job) Census Code 3	Optional	Import a third census code if you wish to further describe jobs.	41 CFR § 60-2.14(c )(1); 41 CFR § 60-2.14(d)
Column O Job Group Code	Optional but Recommended	Job Groups are groups of jobs within the same EEO category that have similar wages, responsibilities, and opportunities for advancement. Job Group Codes can be any alpha/numeric code that describe Job Group Titles, but if they are not imported, the program will assign random codes during import. Read more about forming Job Groups here. Job Group Codes allow the software program to differentiate between individual jobs more precisely than it can using Job Group Names. Regulations allow contractors of fewer than 150 company-wide employees to use EEO-1 categories as job groups; this implies that companies of 150+ should at least consider splitting job groups beyond EEO categories.	41 CFR §§ 60-2.12, 2.13, 2.14, 2.15, 2.16
Column P Job Group Name	Required	Job Groups are groups of jobs within the same EEO category that have similar wages, responsibilities, and opportunities for advancement. Job Group Names can be any general descriptor of the jobs the groups comprise. Read more about forming Job Groups here. Job Group Names allow users and readers to quickly identify the types of jobs the group comprises. Regulations allow contractors of fewer than 150 company-wide employees to use EEO-1 categories as job groups; this implies that companies of 150+ should at least consider splitting job groups beyond EEO categories.	41 CFR §§ 60-2.12, 2.13, 2.14, 2.15, 2.16
Column Q Hire Date	Required	Hire Date here means original hire date. (Rehire dates may be included as any user-defined field (see columns AF-AO below.) Hire dates should be imported in MM/DD/YYYY format. Hire dates are used only in the optional Compensation Analysis, but are required to be submitted with employee data in an audit.	41 CFR § 60-2.17(b)(3)
Column R Date of Birth	Required if Maintained	Date of Birth is each employee’s birth date in the MM/DD/YYYY format. Because Directive 2018-05 issued August 24, 2018 allows age to be used as a proxy control variable for prior experience when analyzing compensation data, the OFCCP may require date of birth to be submitted with employee data in an audit	Directive 2018-05
Column S Salary Code	Required if Maintained	Salary Codes are company-assigned salary or wage codes. The OFCCP requires salary codes to be submitted with employee data in audits.	41 CFR § 60-2.17(b)(3)
Column T Base Salary	Required	Base salaries are the annual, hourly, weekly, bi-weekly, semi-monthly, or monthly base pay of employees, not including bonuses, overtime or other additional income. The OFCCP requires base salary to be submitted with employee data in audits. The software can analyze your base or total compensation data in a salary regression analysis.	41 CFR § 60-2.17(b)(3)
Column U Salary Basis	Required	Salary Basis is a descriptor of the pay in the Base Salary field. If the amount shown in the base pay column is an annual rate, indicate “A” in this column. If it is hourly, indicate “H.” If it is weekly, indicate “W.” If it is bi-weekly, indicate “B.” If it is semi-monthly, indicate “S.” If it is monthly, indicate “M.” Salary Basis is required to be submitted with employee data in audits. The OFCCP requires salary data to be submitted with employee data in audits.	41 CFR § 60-2.17(b)(3)
Column V Hours Worked Per Week	Required	Hours Worked Per Week are the total number of hours an employee works in a typical workweek. In order to analyze part time against full time salaries within a group, the software must calculate the full-time equivalent of part-time salaries using total hours worked per week. The OFCCP requires salary data to be submitted with employee data in audits.	Voluntary Guidelines for Self-Evaluation of Compensation Practices for Compliance with Nondiscrimination Requirements of Executive Order 11246; 6/16/06
Column W Part-Time?	Required	Part Time status here is defined by your company; use a value of “PT” or “Yes” to indicate that employee works part time. Use FT or “No” to indicate full time status. In order to analyze part time against full time salaries within a group, the software must be able to identify part time workers in order to calculate their full-time equivalent salary. The OFCCP requires salary data, including part-time status, to be submitted with employee data in audits.	Voluntary Guidelines for Self-Evaluation of Compensation Practices for Compliance with Nondiscrimination Requirements of Executive Order 11246; 6/16/06
Column X Total Salary	Required	Total salary includes base pay plus bonuses, overtime and any other additional income earned in the 12 months prior to your current AAP year. The OFCCP requires salary data to be submitted with employee data in audits. The program can analyze your base or total compensation data in a regression analysis.	41 CFR § 60-2.17(b)(3)
Column Y Confidential Salary?	Optional	The Confidential Salary field, if populated with a “Y,” will suppress individual employees’ salaries from relevant reports. Typically this field is used for salaries of only high-level management, hence this field should be used sparingly.	N/A
Column Z Supervisor’s ID	Required	Supervisor ID is the Employee ID of each employee’s supervisor. By regulation, all employees who work at one location but report to a manager at another location must be identified and counted in the AAP of the reporting location. The program identifies these individuals by comparing each employee’s work location against their manager’s work location; for this to work properly, the supervisor ID must match an employee ID in the same imported data. The software uses supervisor IDs also to determine the manager of each unit in an Organizational Display or Workforce Analysis as required.	41 CFR §§ 60-2.1 (d)(1), (2), (3); 41 CFR §§ 60-2.11 (a), (b), (c )
Column AA Manual Annotation	Optional	The program creates its own annotations using supervisor versus employee IDs and locations to satisfy regulations requiring employees’ work and reporting locations to be disclosed. Importing your own annotations is an option that should be used only if you understand regulations completely. Manual annotations override automatic annotations in the program.	41 CFR § 60-2.1(e)
Column AB Pay Analysis Group	Optional	Pay Analysis Groups (PAGs) represent groups of employees from one or more job titles who are comparable for purposes of analyzing pay practices. It is not recommended that PAGs be used unless you have an understanding of the potential implications.	Directive 2018-05
Column AC Veteran?	Required	This field is for reporting employees’ Protected Veteran status. Indicate “Yes” if an employee has self-identified as a protected veteran, and “No” if the employee has not self-identified as a protected veteran or has declined to self-identify. For contractors who are subject to VEVRAA, veteran status is required to be collected at the applicant and new hire stages of employment. Veteran status is currently not used in any workforce reports, but this data is required in subsequent AAP years in the Data Collection Analysis of Protected Veterans. Read more about veterans here.	41 CFR § 60-300.42 (a), (b), (c ), (d), (e), (f), (g); 41 CFR § 60-300.44 (k)
Column AD Disabled?	Required	This field is for reporting Individuals With Disability status. Indicate “Yes” if an employee has self-identified as an individual who has a disability, and “No” if the employee has not self-identified as disabled or has declined to self-identify. Read more about Individuals with Disabilities here. Disability status is required to be reported in a utilization report of Individuals with Disabilities.	41 CFR §§ 60-741.42 (a), (b), (c ), (d), (e), (f), (g); 41 CFR § 60-741.44 (k); 41 CFR § 60-741.45
Column AE Force Into Location	Optional	The Force Into Location field is intended to be used only for reporting employees in FAAPs. To utilize this column, specify the Location Code or the FAAP in which you want employees to be counted. The Complete AAP will count each employee’s demographic information in the location specified in the Force Into Location column while retaining the employee’s original Location Code to create an annotation describing work and reporting locations. If this field is left blank, employees are reported according to establishment AAP regulations.	N/A
Columns AF-AO User- Defined Fields 1 – 10	Optional	User-Defined fields can be any 10 alpha/numeric or date factors that affect pay. Examples include: date of last increase, years of experience, rehire date, tenure, date in current job, years of higher education, education level, performance rating, etc. Change the header title to indicate the contents of the column. Regulations require that contractors evaluate their compensation practices and UDFs can help explain disparity in an optional* salary regression analysis run from TCAAP; further the OFCCP would require additional pay factors to be submitted in an audit. *You may consider running a salary regression from TCAAP only by request of a company attorney and for internal purposes only.	41 CFR 60-2.17(b)(3); Voluntary Guidelines for Self-Evaluation of Compensation Practices
Column AP Exclude Employee?	Optional	This field requires a “Yes” value to exclude employees. This field should be used sparingly, but there may be instances when you may wish to exclude an employee’s demographic data from reports; e.g.: you may have employees who work at one facility, but report to another for which you are not preparing an AAP. In these instances, regulations require that the employees appear in your AAP, but that their demographic information be counted in the AAP that covers their manager’s work location.	N/A
Column AQ Commissions	Optional but Recommended	According to the Department of Labor, “A sales commission is a sum of money paid to an employee upon completion of a task, usually selling a certain amount of goods or services.” Regulations require that contractors analyze their compensation practices; the suggested method is to run a regression analysis. In lieu of analyzing Base Salary or Total Salary, you may analyze Commissioned salary.	41 CFR 60-2.17(b)(3); OFCCP Directive 2018-05.
Column AR Overtime	Optional but Recommended	Overtime salary is payment for any hours worked over 40 in a work week. Regulations require that contractors analyze their compensation practices; the suggested method is to run a regression analysis. In lieu of analyzing Base Salary or Total Salary, you may analyze Overtime salary.	41 CFR 60-2.17(b)(3); OFCCP Directive 2018-05.
Column AS Bonuses	Optional but Recommended	According to the Fair Labor Standards Act, “A bonus is a payment made in addition to the employee’s regular earnings.” Regulations require that contractors analyze their compensation practices; the suggested method is to run a regression analysis. In lieu of analyzing Base Salary or Total Salary, you may analyze Bonuses.	41 CFR 60-2.17(b)(3); OFCCP Directive 2018-05.
Column AT Merit Increases	Optional but Recommended	According to the Department of Labor, “Merit Pay, also known as pay-for-performance, is defined as a raise in pay based on a set of criteria set by the employer.” Regulations require that contractors analyze their compensation practices; the suggested method is to run a regression analysis. In lieu of analyzing Base Salary or Total Salary, you may analyze Merit Increases.	41 CFR 60-2.17(b)(3); OFCCP Directive 2018-05.
Column AU Locality Pay	Optional but Recommended	Locality Pay relates to the region where the employee works. The concept of Locality Pay allows for a difference in the base rate of pay for the cost of living in a geographic area. Though specific to federal employees, you can find locality pay tables here at the Office of Personnel Management’s website. Regulations require that contractors analyze their compensation practices; the suggested method is to run a regression analysis. In lieu of analyzing Base Salary or Total Salary, you may analyze Locality Pay.	41 CFR 60-2.17(b)(3); OFCCP Directive 2018-05.
Column AV Incentives	Optional but Recommended	Incentives are generally considered to be compensation awarded for results rather than for time worked. Incentives vary from company to company, but you can learn more about them at the DOL’s website. Regulations require that contractors analyze their compensation practices; the suggested method is to run a regression analysis. In lieu of analyzing Base Salary or Total Salary, you may analyze monetary Incentives.	41 CFR 60-2.17(b)(3); OFCCP Directive 2018-05.

Employment Activities

What are Employment Activities?

Employment Activities Data, also known as personnel activities, impact ratio activities, or adverse impact activities, include applicants, hires, terminations, promotion out of jobs, promotions into jobs, and promotions within jobs. These activities are usually obtained from exports from a company’s HRIS or payroll, and Applicant Tracking System, but might also be tracked and maintained using simple spreadsheets. If your company did not track data in the prior year, you may move forward to Format & Import Workforce Data at this time; you should also visit the New Government Contractor section in AAP Basics to learn more about your tracking obligations.

Dates Are Important!

The activities data comprise the activities that occurred during the 12 months preceding the start of the AAP year, including: applicants, hires, promotions, and terminations. For example, if your AAP dates are January 1, 2024 to December 31, 2024, then you will gather applicant, hire, promotion and termination records for the period January 1, 2023 to December 31, 2023.

If you need help determining the employment activities reporting year, visit our online AAP Date Calculator.

Employment Activities Template

Download Your Employment Activities Template

The Complete AAP expects an exact number of columns in an exact order during import of any data; the column order of a given import is laid out in a template. Click here to download your Employment Activities Data import template. Check your Downloads folder to find the downloaded employment_activities_template.csv file, and save it in an easily-accessible folder. The goal is to pull a data file from your data system(s),copy columns from that source(s), and paste the columns into the template; alternatively, you may develop a query that pulls data from your system(s) in the template order; however, it is unlikely one data system holds all that you’ll need.

Employment Activities Data Template Definitions

The Employment Activities Data Template Definitions list below is a vertical list of the headers in the employment_activities_template.csv. This data helps produce several reports required by OFCCP regulations, directives, or audits, but the term Required in the listing below may refer to either software or regulation requirements. In general, include every field that you are able to gather or develop for each employee.

Column	Required?	Description & Why You May Need It	Supporting Regulations
		…………………………………………………………………………………………..	……………………………………
Column A Location Code	Required	Location Code represents the code of the facility where employment activity occurred. Location codes that correspond with those in the workforce data file ensure that employment activities are reported accurately.	41 CFR § 60-2.1 (b)(1); 41 CFR § 60-2.1 (e); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); Federal Contract Compliance Manual (FCCM) Chapter 10
Column B Activity Code	Required	Regulations require that contractors perform an in-depth analysis of their total employment process, including an analysis of personnel activities to determine whether there are selection disparities. The OFCCP during an audit at a minimum examines the activities below, but can may also examine “other personnel actions.” The program allows you to import records for and analyze activities beyond those listed below. TCAAP recognizes the codes shown below but your import data do not necessarily need to reflect the codes, as the importing process will have you map to them and to create codes for custom activities. APP: *all qualified individuals who applied during the reporting period. HIRE: those hired or rehired during the reporting period PROFROM: employees promoted out of or within jobs PROTO: employees promotions into jobs TERMVOL: employees separated from the company voluntarily TERMINV: employees separated from the company involuntarily PRIORWORKFORCE: see the Prior Workforce section below this table	41 CFR § 60-2.17 (b)(2); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); 41 CFR 60-300.44(k); Federal Contract Compliance Manual (FCCM) Chapter 10
Column C Activity Date	Required	Activity Date should reflect the date the activity in question occurred. The date of the activity should be within the range of the reporting period (visit our date calculator to determine your date range), which is the 12 month period prior to the beginning date of your current AAP.. Activity Dates limit the analysis of employment activity to only the 12-month range required, but options described in the Publish AAP Documents chapter can extend the limits.	41 CFR § 60-2.17 (b)(2); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); 41 CFR 60-300.44(k); Federal Contract Compliance Manual (FCCM)
Column D Individual’s ID	Optional but Recommended	The company-assigned employee identification code on the date the activity occurred. Individual’s IDs help TCAAP and the software user identify individuals’ records for cross-referencing purposes.	N/A
Column E Individual’s Name	Required	This field is intended to hold the name of the individual to whom the activity applies. Regulations do not require employee names to appear in AAPs and TCAAP default settings ensure that they do not, but the use of names allows you to more easily identify the individuals involved should an issue need to be researched. Again, employee names in the Activities table will not appear by default in any reports, but you may be asked to submit them and associated employment activities data during audit.	N/A
Column F Race	Required	Races are the EEOC-recognized race/ethnicity designations. If an individual has not disclosed his or her race, visual determination is permissible. Race designations are necessary in order to determine whether disparity exists in the placement or termination of individuals by race.	41 CFR § 60-2.17 (b)(2); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); Federal Contract Compliance Manual (FCCM) Chapter 10
Column G Gender	Required	Gender here means the binary gender designations recognized by the EEOC: male and female. If an individual has not disclosed his or her gender, visual determination is permissible. Gender designations are necessary to determine whether disparity exists in the placement or termination of individuals by gender.	41 CFR § 60-2.17 (b)(2); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); Federal Contract Compliance Manual (FCCM) Chapter 10
Column H Veteran?	Required	This field is for reporting employees’ Protected Veteran status. Indicate “Yes” if an employee has self-identified as a protected veteran, and “No” if the employee has not self-identified as a protected veteran or has declined to self-identify. For contractors who are subject to VEVRAA, veteran status is required to be collected at the applicant and new hire stages of employment. Veteran status is required to run an accurate Data Collection Analysis of Protected Veterans.	41 CFR § 60-741.42; 41 CFR § 60-741.44 (k)
Column I Disabled?	Required	This field is for reporting Individuals With Disability status. Indicate “Yes” if an employee has self-identified as an individual who has a disability, and “No” if the employee has not self-identified as disabled or has declined to self-identify. Disability status in the Activities table is required to be reported in the required Data Collection Analysis of the affirmative action plan for individuals with disabilities.	41 CFR § 60-300.42; 41 CFR § 60-300.44 (k)
Column J Date of Birth:	Optional but Recommended	Indicate the birth date of the individual. Directive 2018-05 issued August 24, 2018 states that age may be used as a proxy control variable for prior experience in a desk audit.	Directive 2018-05
Column K Job Group Code	Required	Job groups are groups of jobs within the same EEO category that have similar wages, responsibilities, and opportunities for advancement. Job Group Codes should be consistently assigned Job Group Names (i.e. two different titles should not share one code), they should be consistently assigned to jobs (i.e. job_ Accountant_ should not appear in group 2A and in group 2B), and they should correlate to job group codes in the workforce data.	41 CFR § 60-2.17 (b)(2); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); Federal Contract Compliance Manual (FCCM)
Column L Job Group Name	Required	Job groups are groups of jobs within the same EEO category that have similar wages, responsibilities, and opportunities for advancement. Job Group Names should be consistently assigned to Job Group Codes and jobs, and they should correlate to job group names in the workforce data.	41 CFR § 60-2.17 (b)(2); 29 CFR Part 60-3.4 – Uniform Guidelines On Employee Selection Procedures (1978); Federal Contract Compliance Manual (FCCM) Chapter 10
Column M Job Code	Required if imported in Workforce data	Job Codes are company-assigned identifiers for job titles. Job Codes should be consistently assigned Job Names and Job Group Codes, and they should correlate to job codes in the workforce data – whether provided by you or generated by the program.	N/A
Column N Job Title	Required	Job Titles refer to the company-assigned titles that describe the work an employee performs or an applicant is expected to perform. Job Titles should be consistently assigned to Job Codes and Job Group Codes, and they should correlate to job titles in the workforce data.	N/A
Column O EEO Code	Optional but Recommended	EEO codes are job categories determined by the EEOC and are used in affirmative action as the basis for forming Job Groups. Providing them here allows the software user one more source for cross-referencing data when inconsistencies in data are present.	N/A
Column P Requisition Code	Required if Maintained	If an applicant record is associated with a requisition, please provide the requisition code. Each unique requisition code should have only one requisition name. Requisition Codes, if maintained, are required to produce an accurate Data Collection Analysis of Protected Veterans and of Individuals with Disabilities.	N/A
Column Q Requisition Name	Required if Maintained	If the record is associated with a requisition, please provide the requisition name. Each unique requisition name should be assigned to only one requisition code. Requisition Codes, if maintained, are required to produce an accurate Data Collection Analysis of Protected Veterans and of Individuals with Disabilities.	N/A
Column R Department Code	Required if Maintained	Include the Department Code involved in the personnel activity. If data is submitted for audit by Job, department data must also be included.	N/A
Column S Department Name	Required if Maintained	Include the Department Name involved in the personnel activity. If data is submitted for audit by Job, department data must also be included.	N/A
Column T Force Into Location Code	Optional	The program has a tool explained later in this manual that allows you to roll entire locations’ employment activities data into another AAP, but if you wish to report individuals in a location other than the one shown in the Location column, include the force into location code in this column.	N/A
Column U Disposition Code	Optional but Recommended	If you wish to include disposition codes, please do so in this field. Disposition codes can help you easily filter out candidates who did not meet the Internet Applicant criteria and can provide explanations for any disparity uncovered in analyses performed.	N/A
Column V Referral Source	Optional but Recommended	If you wish to include a referral source, please do so in this field. The program allows referral source to be used as a filter in Disparity Analyses, which can help you determine which referral sources are or are not successfully yielding applicants from protected groups.	N/A
Column W Pay Analysis Group	Optional	Pay Analysis Groups (PAGs) represent groups of employees from one or more job titles who are comparable for purposes of analyzing pay practices. The program allows PAGs to be used as a filter in Disparity Analyses, but this is recommended only if you have an understanding of the potential implications.	N/A

Prior Workforce

“Prior Workforce Data” is defined essentially the same as Workforce Data except that it represents a workforce snapshot one year prior to the current AAP year Workforce Data.

What does “one year prior” mean?

• If your current AAP dates are January 1, 2024 to December 31, 2024, then:
  • your prior workforce snapshot should include all active employees as of January 1, 2023.
    
    
    

Consider the circumstances below to determine how to proceed.

• If your company prepared its last AAP in TCAAP and the AAP has been retained, you do not need to gather prior workforce data .
  
  
• If your company prepared its AAP in a different software program, obtain a copy of the workforce snapshot used in it and prepare it using the template guidelines above.
  
  
• If your company does not have a prior AAP in place at all, you do not need to gather prior workforce data.
  
  
• If you are unable to obtain the prior year’s workforce snapshot you do not need to gather prior workforce data.

Other Data

What Other Data Do I Need to Gather?

The data outlined above represent the major and most time-consuming data that you have to gather, but as you work your way through the AAP process you will discover whether and what additional, less-cumbersome data needs to be gathered.

Proceed to Format & Import Workforce Data.

Frequently Asked Questions

Are the dates described in your examples under What is Workforce Data/Employment Activities wrong? I think they’re wrong.

They are most assuredly not incorrect. Probably the most confusing aspect of affirmative action is the year an AAP should cover. What confuses most contractors is the fact that the bulk of the data analyzed in an AAP occurred in the past, therefore the natural but inaccurate inclination is to assume that the employment activity reporting period is your AAP year. The employment activity reporting period is not your AAP year because an affirmative action plan is forward-looking. One way to understand it is to think of the word plan in “affirmative action plan;” it is impossible to plan for the past, so your AAP is a plan for the future year. This plan for the future has you establishing your goals at the beginning of the year, and allowing yourself 12 months to meet them. An OFCCP FAQ offers a dated, but exact description of what OFCCP considers to be a current AAP.

Do I have to include employee names?

Any alphanumeric proxy or alias will work in the Employee Name field; however, it is recommended that you import names because it makes researching individual records immensely easier. The only reports that include employee names are compensation reports that should really be delivered directly to your company’s attorney to maintain attorney client privilege.

Can’t I just type my data directly into the program?

You can manually type in your data, but importing is recommended in almost all cases. Instructions for adding, editing, and deleting records in the program are included in the Review Workforce Data and Review Remaining Data chapters.