Creating an Equal Employment Opportunity Plan WHAT IS AN EEOP? The purpose of an Equal Employment Opportunity Plan (EEOP) is to ensure full and equal participation of men and women regardless of race or national origin in the workforce of the recipient agency. A recipient agency is defined as any State or local unit of government or agency thereof, and any private entity, institution, or organization, to which Office of Justice Programs (OJP) financial assistance is extended directly or through such government or private entity. Recipient agencies that meet all of the following criteria are required to maintain an EEOP on file for review by OJP, if requested; have 50 or more employees; and received a total of $25,000 or more in grants or subgrants; and have 3 percent or more minorities in service population (however, if less than 3 percent minorities in service population, an EEOP must still be prepared, but must focus on employment practices affecting women only). Grantees that meet criteria and that receive over $500,000 (or $1 million during an 18 month period) are required to submit an EEOP with their application to the Office for Civil Rights, Office of Justice Programs for review. An EEOP is a comprehensive document that analyzes the agency's workforce in comparison to its relevant labor market data and all agency employment practices to determine their impact on the basis of race, sex, or national origin. The EEOP includes a written analysis that: • provides a statistical profile of the internal workforce by race, sex and national origin • identifies problems in employment practices and procedures • specifies corrective action • forms the basis of ongoing evaluation. CREATING AN EEOP THE SEVEN-STEPS: OVERVIEW • An introduction stating that the plan is current and reflects the time period of the award. • A breakdown of the agency's current workforce by race, sex, national origin, and job category. • A breakdown of the available workforce in the community by race, sex, national origin, and job category. • A comparison of these breakdowns and identification of underutilization, if any. • Specific objectives to address any findings of underutilization. • Specific steps, which will be taken to achieve the above objectives. • A plan to disseminate the EEOP to all employees and to the general public. Civil Rights Requirements of Recipients Important: All recipients, regardless of the type of entity or the amount awarded, are subject to the prohibitions against discrimination in any program or activity and may be required by the Office of Civil Rights, through selected compliance reviews, to submit data to ensure their services are delivered in an equitable manner to all segments of the service population and their employment practices comply with equal employment opportunity requirements. Regulatory Definition: Recipient means any state or local unit of government or agency thereof, and any private entity, institution or organization to which Federal financial assistance is extended through such government or agency. Technique for Determining If EEOP Requirements Apply to Your Agency First, Ask: Who is the Named Grantee? After reviewing the chart on the previous page, a grantee agency or grant manager may think that his/her situation is atypical or unique regarding EEOP requirements and, therefore, cannot determine whether EEOP requirements should apply. To analyze such seemingly complex situations, the following is a simple and helpful self-test: QUESTION: Who is the named grantee? ANSWER: The named grantee is the agency which is named by the Office of Justice Programs (OJP) on the award document and whose chief executive official serves as the signatory for receipt of the OJP grant award. THEREFORE: The named grantee is the agency responsible for preparing or submitting the EEOP. To test your understanding of this simple technique of determining whether, and to what extent, EEOP requirements apply, two typical scenarios appear below: Scenario 1. The City of Sullivan received a COPS Universal Hiring Program grant for over $500,000, to be used for the hiring of ten additional police officers to work at the Sullivan Police Department. The grant was applied for and received in the name of the City, although the funds are being used for salaries at the Police Department. Question 1: Which of the two agencies -- the City or the Police Department -- is required to prepare and submit an EEOP? APPLY THE SELF-TEST BY ASKING: WHO IS THE NAMED GRANTEE? Answer 1: The City of Sullivan, not the Police Department, should prepare and submit an EEOP that reflects the City's workforce. In this case, the named grantee is the City of Sullivan and the City should submit its EEOP. However, because the Police Department is a subgrantee of the grant funds, and the grant is being made specifically to expand the Police Department's workforce, it is critical that the City's EEOP analyze specifically the Police Department's workforce, in addition to the workforce of other citywide agencies. In other words, a generalized EEOP, which combines all of the City‘s employees into one analysis, will NOT meet OCR requirements. It is permissible for the City to submit its citywide plan with a supplement focusing specifically on the Police Department. Scenario 2. The Sullivan Police Department received a COPS Universal Hiring Program grant for over $500,000, to be used for the hiring of ten additional police officers to work at the Sullivan Police Department. The grant was applied for and received in the name of the Police Department, and the funds are being used for salaries at the Police Department. Question 2: Which agency is required to prepare and submit an EEOP? AGAIN, APPLY THE SELF-TEST BY ASKING: WHO IS THE NAMED GRANTEE? Answer 2: The Sullivan Police Department should prepare and submit an EEOP that reflects that agency's workforce. Here, the named grantee is the Sullivan Police Department, which should submit an EEOP. However, if the City of Sullivan has already prepared a citywide EEOP, such an EEOP would be permissible to satisfy the Police Department's EEOP requirements if the EEOP contains a separate section or supplement that analyzes specifically and fully the Police Department's workforce. COMPLETING THE EEOP STEP 1. THE INTRODUCTION The introduction to the EEOP should contain basic information about the recipient agency as well as an overview of its personnel management and operations. Basic information should include the name, address, and phone number of the grantee; project numbers, names and funding levels; and names, addresses, and phone numbers of project directors. Most importantly, the introduction should state the agency's policy of equal employment opportunity as well as the effective date and duration of the EEOP (which must reflect the time period of the grant award), and must be signed into effect by an agency official. The personnel management and operations overview should include a brief summary of the ongoing equal employment opportunity efforts, progress in meeting EEO objectives, and the current status of EEO efforts. STEP 2. GRANTEE'S WORKFORCE ANALYSIS The grantee must provide a statistical breakdown of its current workforce for each job category broken down by gender within each racial, color, and national origin group. These statistics should be converted into percentages. Percentages should reflect the portion of people in each job classification of a given race/sex/national origin. In other words, if the grantee has four professionals -- three white males and one Hispanic male -- the chart will display 3 and 75% in the block for white male professionals, 1 and 25% in the block for Hispanic male professionals, and 0 and 0% in all other professional blocks. STEP 3. COMMUNITY LABOR STATISTICS The grantee must provide a similar statistical breakdown of the available community workforce for each job category broken down by gender within each racial, color, and national origin group. These data may be obtained from various sources, including the local office of the U.S. Department of Labor, Bureau of Labor Statistics in your region, The data should reflect the community, which forms the grantee's hiring pool. These data must be based on the 1990 or later census statistics. As with the grantee's workforce analysis, the community workforce analysis chart should also be converted into percentages. STEP 4. UTILIZATION ANALYSIS A. CHARTS: The grantee will compare its workforce with that of the relevant community in order to determine if, and in what job categories, women and/or minorities (cross-classified by gender) are under-represented in the grantee's workforce. This utilization analysis forms the basis for the plan and will be obtained by comparing the information presented in Step 2, with that in Step 3. Figures should be determined by subtracting the percentages obtained in Step 3, from those obtained in Step 2. In other words, if Hispanic males comprise 25% of the grantee's professional employees, and Hispanic males make up 50% of professionals in the community workforce, 50% would be subtracted from 25%. The resulting figure, -25%, would be placed in the block on the underutilization analysis for Hispanic male professionals. This process should be repeated for all categories. B. NARRATIVE: The second part of the utilization analysis is narrative. In this section, the grantee will interpret the utilization analysis, pointing out areas that are of concern (e.g., "This agency demonstrates an underutilization of Asian American men in the Executive job level, as their representation in the community workforce at that job level is 15% while at our agency it is only 2%"). STEP 5. OBJECTIVES The grantee will address the underutilization identified in Step 4 by setting forth an objective to address such underutilization. This objective must be specific and must be based on the results of the underutilization analysis. For example, an objective, which states, "it is our ambition to have a workforce that is more representative of the community" is too general. A better type of objective would be one that states, "because African-American women are under-represented in the higher levels of our organization in such jobs as Comptroller and Agency Administrator, it is our objective to increase this representation by evaluating our promotional practices to ensure that African-American women are receiving equal opportunity to advance." Objectives should be reasonably attainable and based on a realistic timetable. STEP 6. STEPS TO ACHIEVE THE OBJECTIVES The grantee must then set forth whatever steps it has determined will enable it to meet its objectives. The most effective steps will be those, which directly address the reasons for any underutilization of women and minorities. The grantee should thus attempt to pinpoint the factors, which put women and/or minorities at a disadvantage in this particular organization. STEP 7. DISSEMINATION Finally, the grantee will describe its plan to disseminate the EEOP to all personnel and applicants. This dissemination plan shall include the name of the person designated to implement the Equal Employment Opportunity Program in the agency. Some Other Helpful Tips: Additional sources of community workforce data may be obtained from the U.S. Census Bureau; local, county, and state planning commission; local chamber of commerce; local employment agencies; local social service agencies; city and county planning commissions; state and local institutions of higher education (state universities); and local public libraries. To determine the factors responsible for any underutilization it may be necessary to evaluate the grantee's procedures in regard to recruitment, applications, testing, terminations, disciplinary actions, and promotions. For example, if the grantee's underutilization analysis reflects that blacks or women are under-represented in all job levels, it demonstrates that the grantee is not hiring these individuals in a manner, which would reasonably be expected given their representation in the community. In order to determine what steps would best rectify this situation, the grantee should scrutinize its past recruitment efforts and hiring practices. Perhaps women have not been targeted for recruitment, and thus are not applying to the degree that men are. On the other hand, it is possible that women are applying to the organization in large numbers, but that they are disproportionately rejected for employment. It may be that the required entry-level examination puts women at a disadvantage, or that a height/weight requirement is screening out female candidates. Once the grantee has pinpointed the cause(s) of the underutilization, it can present the best steps for addressing any inequities. Specific organizations and publications can be contacted for recruitment, examinations/test can be revised, and requirements that do not pertain to job performance can be eliminated. The grantee may wish to offer classes that will better prepare women and minorities for entry-level and/or promotional examinations. Tailoring the EEOP to the grantee's particular needs will enhance the likelihood of realizing the objectives creating a balanced and equitable workforce.

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