Data Validation and Audit Reconciliation · We do offer compensation courses at PeopleFluent. Make sure Comp data contains same groups as your AAP Job Group Analysis Check for mismatched

Data Validation and Audit Reconciliation:

Rosemary Cox, SPHR, SHRM-CHP, SR-CAAP

Principal Business Consultant

Minimizing your AAP Risks and Preparing for an Audit

PeopleFluent Proprietary and Confidential

Data is the new science. Big Data holds the answers.

Are you asking the right questions?

– Pat Gelsinger, EMC

Data are just summaries of thousands of stories – tell a few

of those stories to help make the data meaningful.


It’s All About Telling Your Story

Agenda

• Reviewing your data BEFORE you receive an audit notice

• Data files

• Data inconsistencies

• Preparing for the audit submission

• Best practices


It starts with your AAP at plan time

BEFORE you receive the audit notice


When errors are not caught until an audit notice is received,

what happens?

Communication Requirements:

• Communicate plan results to Executives

• Communicate placement goals, benchmarks & utilization goals to management

• Train managers annually on EEO/AA responsibilities

If your original plans are not accurate and you find yourself re-doing the plan at

audit time:

Goals may change entirely - Managers would have been working on original goals. If interviewed

by auditor and goals are now different, violations may occur.

Adverse Impact changes and/or occurs with changes to data - If asked when adverse impact (AI)

was found and what was the outcome of the research, you will have to answer honestly and say at

audit time, which may cause a violation.


Affirmative Action


What data is needed?

• Employee File

• Static snapshot as of your AA plan date

• Hire File

• Information on anyone hired during preceding year

• Promotion File

• Information on anyone promoted during the preceding plan year – need promotion TO

and FROM information

• Transfer File

• Information on anyone who transferred during the preceding plan year – need transfer TO

and FROM information

• Termination File

• Information on anyone who terminated during the preceding plan year

• Applicant File

• All qualified applicant pools associated with each hire in the Hire File for the preceding

year.


Employee File


Employee file feeds the following reports:

Employee File

Work Force

Job Group

Vets/Disabled Utilization

Compensation

Census

Incumbency


Missing race/gender

Job Groups - are job titles in the correct job groups

Mixed EEO/Job Groups

Same Job Titles different Job Groups

Disabled Status - Yes (Y) No (N) Unknown (U)

Veteran Status - Yes (Y) No (N) Unknown (U)

AAP Location - check for missing/incorrect AAP

Annual Compensation - check for missing, is everything annualized (part time to

full time equivalent)

Missing departments

Census Codes - any missing, are they accurate

Does every employee have a manager ID & AAP on the file

Employee File Data Validation


Same Titles Different Spelling Same Title Different EEO/Job Groups

Mixed Compensation Missing Pieces

Employee Data Inconsistencies


History Files


Goal Attainment

Scorecards

Impact Ratio Analysis

Count Reports

Data Collection

History Files Feed:

History

File


Note: for all promotions and transfers there must be a “TO” and “FROM” side of the

transaction.

Validate same information as Employee file plus:

Demotions – check for movement downward in EEO category for transactions coded

as PR / TR.

Promotion Confirmation – does the transaction meet the company definition of a

promotion? Are the TO and FROM side the same? If yes, is that accurate?

Duplicate Transactions – check for multiples of the same transaction on the same

date.

Termination Reason – check for Voluntary (v) Involuntary (i), validate against decode

table.

History File Data ValidationHires, Promotions, Transfers & Terminations


Same To and From Job Title

Missing Termination Reasons

Two Termination Rows, No Rehire Row

Promoted after Termination, no rehire record

History Data Inconsistencies


Applicant File


Hire Impact Ratio

AnalysisHire Counts

Data Collection

Monitoring Scorecards

Applicant File Feeds:


Disabled Status – check for Yes (Y) No (N) Unknown (U)

Veteran Status - check for Yes (Y) No (N) Unknown (U)

EEO Code – validate

Job Group – validate against decode table or last run AAP

Applicant ID – check for missing

Disposition – check for missing, validate against definition of applicant

Requisition – did requisition result in a hire, did requisition result in multiple hires

Requisition with no hires should be removed

Requisitions with only internal hires should be removed

Basic match of Applicant Name into Applicant Log – where match, and disposition

= hired, the information from the hire record trumps the applicant record (Race,

Gender, AAP, Job Group)

Applicant File Data Validation


Hires with Unknown Race/Gender

Non-Applicant Disposition Reasons

One Requisition – Multiple AAPs One Requisition Multiple Job Groups

Applicant Data Inconsistencies


AUDIT PREPARATION


The following reports are due in the event of an audit:

• 3 Narratives

• Work Force Analysis

• Work Force Analysis

Include/Exclude

• Job Group Analysis

• Job Group Analysis

Include/Exclude

• Incumbency v Availability

• Placement Goals

• Compensation Item 19

• Goal Attainment

• Hire, Promotion and Termination Counts

• Veteran Monitoring

• Data Collection

• Utilization Analysis - Disabled

Reports reflect current plan year and

end-of-prior year unless audit notice

comes more than 6 months into your

current plan year, then midyear reports

would also be required

All of these reports must be accurate and reconciled with prior year.


Preparing data for an Audit

• Are correct people in the AAP?

• Are includes/excludes appropriate?

• Are manager/supervisors notated?

• Is compensation data complete?

• Do you have adverse impact in any

area?

» Can you produce documentation?

» Are disposition codes correct?

» Have you performed a step analysis?

• Are transactions correct (hires,

promotions, transfers,

terminations)?

• Do the prior year totals – plus and

minus the transactions –

accurately reflect the current year

totals?


Reconciling/Audit Prep

• Are the Hires accounted for in the

employee file?

• Have terms been removed from the

employee file?

• Is every hire in the applicant file?

• Are there hires in the applicant file

that are not in the hire file?

• Are there instances of duplicate

transactions with no corresponding

action– 2 termination rows but no

rehire row, for example?

• Are there requisitions with hires that

cross AAP’s – has the pool been

duplicated?

• Are there people in prior employee file

in 1 plan but in another plan for

current employee file?

• Can you account for demotions,

laterals and other movement?


In Prior Employee file – Not in current – No term Row

In plan 10 prior year – in plan 20 current – no history record

In previous and current employee file – term row in history with no rehire row

In plan 10 prior and current employee file – termed from plan 12 and no rehire row

Advanced Data Inconsistencies


Comparing 2015 to 2014• 1A +1

• 1B +2

• 1D – 3

• 2B +2

• 2E +4

• 5A +2

• 5B – 2

• 6A +4

• 7B +3

• 8A +23

Should find history

transactions to account for

each difference.

Compare prior year to current year, correct errors or ensure

you can explain discrepancies


Here is the 1A hire to account for difference

Here are 2 hires in 1B to account for difference

But…in 5B there are 3 terms, not 2 – how do

we explain the difference?


Check Include/Excludes to make sure they are correct


Other Items to check


Item #19 Compensation

This is high level, we will not be deep-diving into compensation concerns during this course. We do offer compensation

courses at PeopleFluent.

Make sure Comp data contains same groups as your AAP Job Group

Analysis

Check for mismatched job titles

Check for Mixed columns

Check for anomalies – high merit, low merit, high bonus, low bonus, etc.

Add data that helps explain variances – location, dept, shift, time in

position, etc.

Sort by title, then salary, look for potential disparities

If unsure of accuracy or you see issues in your comp data, consider get an

expert involved.


Best Practices• Review data at time of AAP, do not wait until audit notice is received

– Reconcile prior year with current and review transactions

• Communicate placement goals, Utilization goals and hiring benchmark to anyone who makes

a decision about another person

• Monitor goal progress throughout the year

• Research all adverse impact

• Analyze compensation annually

• Review internal processes and ensure they are followed

• Document all employment decisions (applicant dispositions, hires, promotions, terminations,

compensation, etc.)

• Log all outreach and recruiting efforts

• List all jobs with the local or state workforce agency (3 exceptions)

• Review bulletin boards and tour facilities


Questions

Thank you!

Questions/Comments/Need Help?

[email protected]

Documents

Data Validation and Audit Reconciliation · We do offer compensation courses at PeopleFluent. Make sure Comp data contains same groups as your AAP Job Group Analysis Check for mismatched