Diane Gotch
Diane is the Executive Director of HR Strategic Solutions LLC. Diane has over 30 years of diverse leadership experience in both Human Resources Management and Compliance Program creation.
Prior to joining HR Strategic Solutions, Diane served as the Managing Director at Lincoln Tyler Management. In this role, Diane was responsible for leading the Human Resources consulting and Affirmative Action Program teams. She has worked with numerous clients in the capacity of HR Management, as well as Recruiting, Compensation Analysis and Performance Management. In addition, Diane directed the Affirmative Action Program team, creating Affirmative Action Plans, Diversity and Inclusion Recruiting programs and working with many clients through the process of their OFCCP audit.
Diane also worked at The Sherwin-Williams Company in several positions of increasing responsibility, with the last position being the Director of Human Resources for the Automotive Finishes division. Throughout her 18 year SW career, Diane successfully developed and implemented numerous programs and systems in the areas of Organizational Development, Succession Planning, Performance Management, Recruiting/Interviewing and Placement, Employee Relations, and Training and Development.
Diane has a Masters Degree in Industrial/Organizational Psychology from Cleveland State University and Bachelors Degrees in Psychology and Biology from Grove City College.
Diane can be reached at diane@hrstrategicsolutions.com
Dan Baron
Dan A. Baron is the founding member of HR Strategic Solutions and brings over fifteen years of human resource experience. He holds a business degree from The University of Akron, cum laude and is a member of the Cleveland Metropolitan Bar Association, West Shore Bar Association, Akron Bar Association, and American Bar Association. Dan is also a member of the HR section at the Cleveland Metropolitan Bar Association.
Dan teaches business and human resource at several local colleges including Cuyahoga Community College, Lorain County Community College, and Baldwin Wallace. Dan is a published author and founder of Dollars & Sense Magazine. Most important to Dan is spending time with his family and making contributions to the Cleveland, Ohio community through speaking engagements and community service.
Dan can be reached at dan@hrstrategicsolutions.com
Affirmative Action FAQ
Each non-construction contractor/subcontractor with 50 or more employees is required to develop a written Affirmative Action Program (AAP) for each of its establishments within 120 days from the start of the Federal contract, if it:
- Has a Federal contract or subcontract of $50,000 or more
- Has government bills of lading which in any 12-month period total, or can reasonably be expected to total, $50,000 or more
- Serves as a depository of Federal funds in any amount
- Is a financial institution that is an issuing and paying agent for U.S. savings bonds and savings notes in any amount
An Affirmative Action Plan is a written document containing information and analyses of a federal contractor’s workforce.
The Affirmative Action Plan is comprised of four sections:
- Workforce Analysis
- Utilization Analysis
- Goal and Timetables
- Narrative
The first three sections include employee data, national census data and availability data. This data is used to analyze the demographics of the Company’s workforce in relation to the demographics of qualified and available individuals in the relevant labor pool (local, regional,national, etc.). This data is used to determine what group(s) are underutilized in a given job group and to establish placement goals to address the underutilization.
In addition, the analysis section contains the Disparity Analysis which captures applicant, hire, promotion and termination data from a period prior to the Plan data. This data is analyzed to ensure the contractor has not treated any gender or ethnicity in a disparate manner through these personnel activities during the measured time period.
The plan’s narrative details problem areas that may impede or limit opportunities in all job groups at all levels of the organization, as well as the Company’s commitment and efforts to remedy these inequities and remove barriers.
An Affirmative Action Program is a management tool designed to ensure equal employment opportunity. It includes a list of 22 items such as the policies, practices and procedures the Company implements to address underutilization in its workforce, and to ensure that all qualified applicants and employees receive an equal opportunity for recruitment, retention, selection, advancement, training, development and every other condition and privilege of employment.
According to OFCCP estimates, an average of almost 200 labor hours are required for contractors to create, maintain, and annually update their affirmative action plans.
Also, affirmative action plan documents and analysis are required to be updated annually. Affirmative actions include training programs, outreach efforts, and other positive steps are included in the annual update. Most importantly, though, the availability analysis, utilization analysis, disparity analysis, and all other related statistical analyses must be completed and interpreted annually as well.
When taking into account all of these issues, outsourcing your affirmative action plan responsibilities to qualified plan specialists is the most efficient and cost effective solution to create compliant Affirmative Action Plans.
The Office of Federal Contract Compliance Programs (OFCCP), an agency in the U.S. Department of Labor, is primarily responsible for conducting the contract compliance program to ensure that contractors and subcontractors are in compliance with their obligations under the affirmative action laws and regulations.
OFCCP does this by conducting compliance evaluations (audits), and investigating complaints of discrimination.