During a recent audit experience, a compliance officer insisted that the workforce analysis was incorrect because a supervisor (including name) was not listed for each department. We thought it would be a great time to provide a quick refresher regarding the purpose and development of an organizational profile, in case you are confronted with the same request during an audit.
Purpose
As part of the AAP, federal contractors are required to include an organizational profile in the form of an organizational display or workforce analysis (60-2.11). The purpose of the organizational profile is to provide an overview of the workforce, at each establishment, by gender and race/ethnicity.
Development
The organizational display is a graphic (e.g., chart) that shows the relationship between departments. It displays the following:
- Department/unit name,
- Job title, gender, race/ethnicity of unit supervisor,
- Total number of male and female incumbents, and
- Total number of male and female incumbents by race/ethnicity.
The workforce analysis lists each job title, within a department, from lowest to highest paid. It also includes the:
- Department/unit name,
- Total number of male and female incumbents, and
- Total number of male and female incumbents by race/ethnicity.
However, if there are no formal progression lines within the department, then a supervisor does not have to be included in the workforce analysis. Therefore, if you develop a workforce analysis as part of your AAP, it is not a requirement for the supervisor of each department to be listed.
In addition, note that neither the organizational display nor the workforce analysis provides names for any incumbents (including the supervisor). If during an audit, there are questions regarding the supervisors of incumbents within a particular department, the compliance officer can submit a follow up request for such data. Otherwise, based on the organizational profile developed, “who’s the boss?” would simply be identified via their job title.
by Yevonessa Hall, M.P.S., Associate Consultant, DCI Consulting Group
