As a federal contractor, Colorado State University is an Affirmative Action employer under the jurisdiction of the Office of Federal Contract Compliance Programs (OFCCP). In the language of Executive Order 11246, this means that the University “will take affirmative action to ensure that applicants are employed, and that employees are treated during employment, without regard to their race, color, religion, sex or national origin. Such action shall include, but not be limited to the following: employment, upgrading, demotion, or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay or other forms of compensation; and selection for training, including apprenticeship. The contractor agrees to post in conspicuous places, available to employees and applicants for employment, notices to be provided by the contracting officer setting forth the provisions of this nondiscrimination clause.”
CSU maintains and annually updates an Affirmative Action Plan (AAP) that explains the University’s efforts to meet the letter and spirit of our Affirmative Action obligations for women and federally defined minority groups as well as statistical analyses to understand to what extent our efforts are succeeding and in what areas we should set goals for further improvement. Additionally, the University maintains and annually updates an AAP for protected veterans and persons with disabilities.
Availability Description and Analysis
The availability process requires an analysis of the present quantity and quality of employment of women and minorities within the University to determine if there are areas where the number of incumbent women and minorities is less when compared to the number that would be reasonably expected of women and minority employment candidates available in the recruitment area. If it is found that the number of women and minorities employed at the University is less than the expected availability in the relevant labor market, the University must use its best efforts, in good faith, to develop and implement procedures that are designed to increase the number of qualified women and minority candidates in the applicant pool, which will lead to the establishment of placement goals for women and minorities in areas where they are needed.
The principle of affirmative action requires that aggressive efforts be utilized to employ and advance women and minorities in areas where they are employed in fewer numbers than is consistent with their availability in the relevant labor market. The University’s objective is to employ and promote the best person for the job.
Job Group Analysis (41 CFR § 60-2.12)
1. EEO-6 Categories
For the purpose of conducting meaningful workforce analyses, the University staff is first grouped by occupational duties into segments having broad similarities. These macro-groupings, called EEO-6 categories, are defined in the Higher Education Staff Information (EEO-6) Report for Public/Private Institutions of Higher Education that is issued by the Equal Employment Opportunity Commission. The categories and their corresponding 2-digit identification codes used by the University reports are:
01 Ladder Rank Faculty (Tenure and Tenure track Faculty), Clinical and Research Faculty
03 Non-Ladder Rank Instructional (Non-Tenure track Faculty)
05 Executive, Administrative, Managerial
07 Technical and Paraprofessional
08 Clerical and Secretarial
09 Skilled Crafts
10 Service and Maintenance
2. Job Groups
Within each major category, staff are subdivided into job groups, breaking them into segments with greater similarities, based on the criteria outlined in 41 CFR § 60-2.12(b) and five additional criteria:
a. Jobs within a group have similar content, promotional opportunities, and wage rates or salary patterns.
b. In order to provide meaningful comparisons, job groups closely parallel the employment categories used in published data on the availability of minorities and women.
c. Job groups should take into consideration the reporting structure of the organization.
d. The University strives to have each job group contain a number of employees sufficient for valid statistical analyses.
Job group definitions are developed by the staff of the Office of Equal Opportunity.
Determination of Availability (41 CFR § 60-2.14)
In accordance with Department of Labor guidelines, the following factors are considered in developing an estimate of the availability of women and minorities for each job group:
1. The percentage of minorities and women with requisite skills in the reasonable recruitment area. The reasonable recruitment area is the geographical area from which the employer usually seeks or reasonably could seek employees to fill the positions in a job group.
2. The percentage of minorities and women among those promotable, transferable, and trainable employees within the employer’s organization.
Availability estimates are determined in the following manner: data are sought from reliable published sources on the race, ethnicity, and sex composition of the potential pool relevant to the job group in question. For example, sources for the data used to calculate the availability estimates may include: counts of doctorate degrees by field and recent survey data of Postsecondary Faculty (faculty); nationwide 2006 – 2010 ACS data from the Census (administrative and professional); and Larimer and Weld county 2006 – 2010 ACS data from the Census (state classified). The raw data by race, ethnicity, and sex is then weighted according to the best estimates of the proportions of hires made from each pool so that the sum of factor weights (expressed as a percentage) is 100 percent.
An estimation of the proportion drawn from each pool is done by the Office of Equal Opportunity, using input from units having substantial numbers of staff in the job group. Then, computer files are built containing basic information on raw percentages and the weighting factors. A computer program is used to calculate weighted estimates for each job group, incorporating the required factors.
In the determination of weights, the relevance and applicability of the data obtainable for each pool are important considerations. Specifically, if the source combines several disciplines, because of the small total numbers involved in each, and the proportions of each protected class in the different disciplines are widely spread, the reliability of the source to reflect the true composition of the pool is in question. In such cases, the weighting of that pool would be lowered and the weighting of a more accurate pool would be increased, until better data becomes available.
Once they are computed, the availability estimates give participation standards against which to measure proportions of females and minorities in each job group in the University’s workforce.
Comparing Incumbency to Availability
Once availability has been determined, the analysis of comparing incumbency to availability is a simple yes or no query. Each job group’s minority and female availability figure (a percentage) is compared to the percentage of minority and female incumbents in that job group. If the percentage of incumbents is equal to or greater than the relevant availability figure, then that job group is at “parity” with availability, and there is no establishment of placement goals. If the percentage of female or minority incumbents falls below availability, placement goals are established and are set equal to the percentage of minorities and females that would reasonably be expected in the job group based on availability. This comparison, along with any placement goals that must be set pursuant to 41 CFR § 60-2.16, are set forth in tables found on this page.
Placement Goals (41 CFR § 60-2.16)
1. Establishment of Placement Goals
The establishment of a placement goal does not amount to an admission of impermissible conduct. It is neither a finding of discrimination nor a finding of a lack of good faith affirmative action efforts. Rather, the establishment of a placement goal is designed to be a technical targeting term used exclusively by affirmative action planners who seek to apply good faith efforts to increase in the future the percentage employment of minorities and women in a workforce.
In every job group where underutilization is found, placement goals are set for the entire campus or, in the case of faculty, for each college. A placement goal is defined as the University established target, which the University makes a good faith effort to achieve. Separate placement goals are set for minorities and for women.
2. The Exact Binomial Test
When there is not parity in a job group, a placement goal is set according to the Exact Binomial Test. The Exact Binomial Test calculates the likelihood of hiring the incumbent number of women or minorities (or fewer) for a job group if all employees in the job group were selected without regard to gender or race/ethnicity from an applicant pool with percentages of women and minorities equal to the availability estimation. If that probability is significantly low (less than 0.1), a placement goal is set, with the purpose of working toward the incumbency of women and minorities in a job group mirroring the availability of women and minorities for that job group. A 0.1 (10%) level of significance is used instead of the more common 0.05 (5%), in order to be less lenient and to identify areas with less significant potential underutilization.
a. Placement Goals for Ladder Rank Faculty (Tenure and Tenure track)
For ladder rank faculty, the analysis of comparing incumbency to availability will determine whether minorities and/or women lack parity in the various academic units. Where there is a lack of parity and thus a placement goal for an academic unit, the unit should be aware of the placement goal and consider it in their hiring efforts.
b. Placement Goals for Non-Ladder Rank Instructional Faculty (Non-Tenure)
Many non-ladder rank faculty hold positions of a limited duration. Pursuant to OFCCP guidelines, setting placement goals for temporary employees is not required. Accordingly, no placement goals are set for temporary non-ladder rank faculty.
c. Placement Goals for Non-Faculty Areas
Placement goals are established for all regular non-faculty job groups campus-wide and in each unit where there is a lack of parity between incumbency and availability of minorities and/or women. Each unit should be aware of unit and campus placement goals and consider them in their hiring efforts.
3. Placement Goals
Pursuant to 41 CFR § 60-2.16, whenever the term “placement goal” is used, it is expressly intended that it should not be used to discriminate against any applicant or employee because of race, color, religion, sex, sexual orientation, gender identity, or national origin. All placement goals are voluntarily adopted in a good faith effort to support affirmative action efforts. Where placement goal commitments exceed the percentage estimates of availability, the University acknowledges that these are not required by OFCCP or by order of any court.
Affirmative action placement goal setting at the University is done on a yearly cycle. This cycle grants each unit a horizon in which to develop and carry out its objectives.
Each organizational unit must adopt one or more specific, realistic commitments to be accomplished during the year period. Commitments include both percentage placement goals for any job groups that significantly lack parity between incumbency and availability, as well as programmatic goals.
Tables which summarize campus-wide placement goals for the current Affirmative Action Plan year are displayed on the Office of Equal Opportunity’s website. The tables also display the percentage of women and/or minorities required to achieve full parity between incumbency and availability.
Affirmative Action Utilization and Placement Goals Analysis
The statistical comparison of the number of incumbent women or minorities currently employed in a job group at Colorado State University to the estimated percentages of women or minorities qualified and available to perform that job is called a utilization analysis. CSU employs the Exact Binomial Test to conduct these analyses and identify job groups in which the discrepancy between the demographics of available and incumbent employees is statistically significant, using a 0.1 level of significance. For these job groups, we set hiring placement goals, with the purpose of working toward the incumbency of women and minorities in a job group mirroring the availability of women and minorities for that job group.
Utilization and Placement Goals Analyses of Colleges
- Warner College of Natural Resources
- College of Agricultural Sciences
- College of Health and Human Sciences
- College of Business
- Walter Scott Jr. College of Engineering
- College of Liberal Arts
- College of Natural Sciences
- College of Veterinary Medicine and Biomedical Sciences
Utilization and Placement Goals Analyses of Non-Academic Units
- Enrollment and Access
- External Relations
- Information Technology
- President’s Office
- Provost and Executive Vice President
- Student Affairs
- University Advancement
- University Operations
Governing Agencies, Laws, and Regulations
- Office of Federal Contract Compliance Programs (OFCCP), a division of the U.S. Department of Labor
- U.S. Equal Employment Opportunity Commission (EEOC)
- Executive Order 11246 (as amended)
- The Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA)
- Section 503 of the Rehabilitation Act of 1973 (as amended)
- Code of Federal Regulations section on federal contractor requirements