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									Central Washington University                                          Affirmative Action Programs



                               AFFIRMATIVE ACTION PROGRAMS
                  AFFIRMATIVE ACTION PROGRAM FOR WOMEN AND MINORITIES
                                      [41 CFR § 60-2.10]

I.     Policy Statement [41 CFR § 60-1.4], [41 CFR § 60-2.10 (2) (2)]
           (A copy of the policy, signed by the president, is provided in appendix 1.)

      A. Central Washington University is an equal opportunity employer that values an inclusive
         campus and welcomes a diversity of ideas and people. In keeping with its commitment to
         nondiscrimination, the university:

         1. Recruits, hires, trains, and promotes persons in all job titles, without regard to race,
            color, creed, religion, national origin, sex, sexual orientation, gender identity and
            gender expression, age, marital status, disability, or status as a protected veteran.

         2. Ensures that all personnel actions such as compensation, benefits, transfers,
            terminations, layoffs, return from layoff, university-sponsored training, education,
            tuition assistance, and social and recreation programs, will be administered without
            regard to race, color, creed, religion, national origin, sex, sexual orientation, gender
            identity and gender expression, age, marital status, disability, or status as a protected
            veteran.

      B. University employees will not engage in harassment of others based on their race, color,
         creed, religion, national origin, sex, sexual orientation, gender identity and gender
         expression, age, marital status, disability or status as a protected veteran. Behavior rises
         to the level of harassment when it is unwelcome and creates an intimidating, hostile, or
         offensive work environment.

      C. The office for equal opportunity maintains formal and informal grievance procedures for
         individuals who believe they have been harassed or otherwise discriminated against in
         their capacity as employees or applicants. Individuals who file complaints or otherwise
         participate in the grievance process will not be retaliated against.

      D. Central Washington University is also committed to affirmative action for Asians/Pacific
         Islanders, Blacks, Hispanics, American Indians/Alaskan Natives, women, persons forty
         years of age or older, persons of disability, and protected veterans. This commitment is
         expressed through the university's efforts to eliminate barriers to equal employment
         opportunity and to improve employment opportunities encountered by these affected
         groups.

      E. Staci Sleigh-Layman, interim director of the office for equal opportunity, has the
         responsibility for CWU's affirmative action program. The office for equal opportunity is
         located in Barge Hall, room 211, telephone (509)963-2205, TDD (509)963-2207.

II.    Procedures for Dissemination of Policy

       A.    Internal Dissemination - Central Washington University will disseminate its
             affirmative action policy internally as follows:

             1.    The president of the university will annually express commitment to the policy
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               by either circulating a signed letter to all departments or through other forms
               of communication. In addition the policy (CWUP 2-2.1) is included in the
               university's policy manual that is readily available to all departments,
               employees and members of the public on the university’s website.

          2.   The director of equal opportunity will publicize it on the university’s website
               continually, and each October in the university's newspaper, The Observer.

          3.   On an ongoing basis the director of equal opportunity will meet with the vice
               presidents and other administrators and supervisory personnel to explain the
               intent of the policy and individual responsibilities for effective implementation,
               reaffirming the president's affirmative action commitment. The office for
               equal opportunity and department of human resources will work together to
               provide institution-wide data on a quarterly basis to president’s cabinet.

          4.   Administrators and supervisory personnel will meet with other employees to
               discuss the policy and explain individual employee responsibilities at least
               annually.

          5.   The office for equal opportunity, through new employee orientation
               (conducted by the department of human resources) and new faculty
               orientation (conducted by faculty relations) will ensure the distribution of the
               policy and discussion of the university's commitment to equal opportunity and
               affirmative action during orientations for new employees each year. The
               department of human resources will include a copy of the policy in all new
               employee packets on an ongoing basis.

          6.   The assistant vice president for human resources and assistant vice president
               for faculty relations will include nondiscrimination clauses in all union
               agreements and review all contractual provisions on an ongoing basis to
               ensure they are nondiscriminatory. [41 CFR § 60-1.4 (a)(3)]

          7.   The office for equal opportunity will post the policy on strategic university
               bulletin boards.

     B.   External Dissemination - Central Washington University will disseminate its
          affirmative action policy externally as follows:

          1.   The office for equal opportunity will annually inform all employment recruiting
               sources of the university's affirmative action policy and encourage their
               referral of minorities and women for job posting they will receive throughout
               the year.

          2.   The assistant vice president for human resources and director of business
               services and contracts will incorporate the equal opportunity clause in all
               purchase orders, leases, contracts, etc., covered by executive order 11246, as
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                 amended, and it’s implementing regulations on an ongoing basis. [41 CFR §
                 60-1.4 (a) (7)]

            3.   The office for equal opportunity and department of human resources will
                 regularly communicate to prospective employees the existence of the
                 university's affirmative action program and make available such elements of its
                 program as will enable such employees to know and avail themselves of its
                 benefits. [41 CFR § 60-1.4 (a) (2)]

            4.   The director of business services and contracts will provide written notification
                 of university policy to contractors, vendors and suppliers on an ongoing basis.
                 [41 CFR § 60-1.4 (a) (7)]

            5.   The vice president for business and financial affairs, the vice president for
                 student affairs and enrollment management, the vice president for university
                 relations and the director of public relations and marketing will insure that
                 diversity is positively represented in handbooks and publications on an
                 ongoing basis.

III.   Responsibility for Implementation of Program

       A.   The overall responsibility for the effective implementation of the affirmative action
            program rests with the president of the university, who will:

            1.   Assign operating responsibility for implementation of the program to
                 administrators as appropriate.

            2.   Provide the necessary top management support and staffing to the director of
                 the office for equal opportunity to execute assigned duties within available
                 funds.

            3.   Reaffirm the university's commitment to affirmative action annually,
                 disseminating this reaffirmation of the policy both internally and externally.

       B.   Specific authority and responsibility for the administration of the program will be
            delegated to the director of the office for equal opportunity who will:

            1.   Develop policy statements, affirmative action programs, and goals, and
                 internal and external communication techniques in cooperation with others.

            2.   Identify problem areas. [41 CFR § 60-2.17 (b)]
            3.   Assist the administration in the development and execution of action oriented
                 program to address the problem areas identified. [41 CFR § 60-2.17 (c)]

            4.   Design and implement audit and reporting systems that will:

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               a.    Measure effectiveness of the university's programs.

               b.    Indicate need for remedial action.

               c.    Determine the degree to which the goals and objectives have been
                     attained. [41 CFR § 60-2.17 (d)]

          5.   Serve as liaison between the university and enforcement agencies.

          6.   Serve as liaison between the university and minority organizations, women's
               organizations and community action groups concerned with employment
               opportunities of minorities and women.

          7.   Keep administration informed of the latest developments in the entire equal
               opportunity area.

          8.   Report annually to the university’s president and vice presidents on the
               university's affirmative action activity and progress in relation to the program
               and the university goals and objectives. [41 CFR § 60-2.17 (d) (4)]

          9.   Monitor personnel actions to ensure compliance with affirmative action
               requirements. [41 CFR § 60-2.17 (d) (1)]

          10. Keep an "applicant flow record" for each position filled, indicating as far as
              available for each applicant: name, race, ethnicity, sex, disability status,
              protected veteran status, and referral source. [41 CFR § 60-3.4 A, B]

          11. Provide for necessary internal informational and training activities designed to
              increase awareness of all employees to the requirements and benefits of
              affirmative action and equal opportunity. [41 CFR § 60-250.44 (j)], [41 CFR §
              60-741.44 (j)]

     C.   Deans, department chairs, and academic program directors will be responsible for
          the administration and implementation of the applicable portions of the program as
          a basic part of their jobs. Line responsibilities include, but are not limited to, the
          following:

          1.   Assist the director of the office for equal opportunity in the identification of
               problem areas and establishment of goals and action oriented programs to
               address identified deficiencies.

          2.   Ensure that criteria used or developed by search committees to select faculty
               and exempt employees are effective predictors of successful job performance
               for the particular job or jobs in question and that they do not have an adverse
               impact on minorities, women, the disabled, or protected veterans.

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          3.   Conduct annual audits of professional development opportunities, and hiring
               and promotion patterns to remove impediments to the attainment of goals
               and objectives.

          4.   Initiate regular discussions with faculty and staff to be certain that university
               equal employment/affirmative action policies are understood and are being
               followed.

          5.   Periodically audit assigned units to ensure that:

               a.    Affirmative action/equal employment opportunity policy statements are
                     properly displayed.

               b.    All facilities that the university maintains for the use and benefit of
                     employees are, in fact, desegregated, both in policy and use. Facilities
                     exempt from this requirement such as dormitories, locker rooms and rest
                     rooms must be comparable for both sexes. [41 CFR § 60-1.8]

               c.    Minority and female employees are afforded a full opportunity and are
                     encouraged to participate in all university-sponsored educational,
                     training, recreational and social activities. [41 CFR § 60-20.3 – sex
                     discrimination guidelines]

          6.   Take actions to prevent harassment of employees placed through affirmative
               action efforts. [41 CFR § 60-250.44 (e)]

     D.   Non-academic program directors, managers, and supervisors will be responsible for
          the administration and implementation of the applicable portions of the program as
          a basic part of their jobs. Responsibilities will include, but not be limited to, the
          following:

          1.   Conduct annual audits of professional development opportunities, training
               programs and hiring, promotion and termination patterns to determine
               whether impediments exist for women and minorities. When impediments are
               identified, action will be taken to address them.

          2.   Initiate regular discussions with staff to be certain that university equal
               employment opportunity policies are understood and followed.

          3.   Review the qualifications of all employees to ensure that protected group
               members are given full opportunity for transfers and promotions.

          4.   Ensure that pre-employment inquiries that have a disproportionate impact on
               members of protected groups are not used in the selection and placement
               process.

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          5.   Provide career counseling for employees on request or refer them to the
               department of human resources.

          6.   Periodically audit assigned units to ensure that:

               a.    Affirmative action/equal employment opportunity policy statements are
                     properly displayed.

               b.    All facilities that the university maintains for the use and benefit of
                     employees are, in fact, desegregated, both in policy and use. Facilities
                     exempt from this requirement such as dormitories, locker rooms and rest
                     rooms must be comparable for both sexes.

               c.    Minority and female employees are afforded a full opportunity and are
                     encouraged to participate in all university-sponsored educational
                     training, recreational and social activities.

          7.   Take actions to prevent harassment of employees placed through affirmative
               action efforts.

     E.   The following specific responsibilities will be implemented by the designated official
          noted below:

          1.   The president will ensure that evaluations of all administrators will address
               their affirmative action/equal employment opportunity efforts and results.

          2.   The vice president for business and financial affairs, the provost and senior vice
               president for academic affairs, the vice president for student affairs and
               enrollment management, and the vice president for university relations will:

               a.    Ensure that the responsibilities assigned to academic and non-academic
                     administrators, managers, and supervisors are carried out.

               b.    Continuously evaluate the selection standards and procedures utilized by
                     the university to ensure that the practices do not discriminate, but
                     instead contribute toward affirmative action goals.

          3.   The vice president for business and financial affairs, the vice president for
               student affairs and enrollment management, the vice president for university
               relations and the director of public relations and marketing will insure that all
               publications produced by the university for external or internal distribution
               contain an affirmative action/equal opportunity statement and the name of
               the person responsible for administration of the program.

               Photographs published in conjunction with university informational and other
               publicity documents will, where appropriate, illustrate the university's student
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                 and employee mix with regard to minority, female and disabled participation.

           4.    The assistant vice president for financial affairs, through the director of
                 business services and contracts, and the assistant vice president for facilities
                 management shall comply with federal, state, and local nondiscrimination
                 policies and procedures when soliciting bids on all contracts for construction,
                 goods, and services. They will solicit bids from women and minority group
                 vendors and contractors. They will notify agencies engaged in business with
                 the university in writing of the university's affirmative action program and ask
                 these agencies to provide a statement of nondiscrimination.

                 In the case of federal contracts for research grants and awards, the dean of
                 graduate studies and research will be charged with development and inclusion
                 in any contract a statement of nondiscrimination in the fulfillment of such
                 contract.

IV.   Utilization Analysis

      A.   Workforce Profile [41 CFR § 60-2.11] (See appendices 2-6 for current workforce
           profiles.)

           1.    Workforce analyses display the existing workforce by race/ethnicity, sex,
                 disability, age 40 and over, and status as a disabled veteran or Vietnam era
                 veteran. Information is presented in detail by job title, job group, and
                 department or organizational unit. Information is also presented institution-
                 wide by job group, indicating headcount. (See appendix 2 for detailed list of
                 job groups.)

                 a.    Because of multiple reporting relationships, institutional complexities,
                       informal and frequently changing relationships amongst the different
                       types of employees, the university is unable to show reporting
                       relationships beyond indicating the administrator of each unit. Upon
                       request, by an OFCCP Compliance Officer, individual departments within
                       the institution will provide detailed charts of the reporting relationships
                       within the departments.

                 b.    To protect confidentiality, disability, age 40 and over, and status as a
                       disabled veteran or Vietnam era veteran data are reported only at the
                       institution-wide level. Displaying data at the organizational unit level
                       would be equivalent to identifying individuals.

           2.    The university annually produces the following workforce displays:

                 a.    Workforce Profile 1 (appendix 2):
                       Display of the workforce, institution-wide
                         within the institution by job group
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                       within job group by salary groups
                        total and percent of each job group and all job groups

               b.   Workforce Profile 2 (appendix 3):
                    Display of the workforce, institution-wide
                      within the institution by job group
                       within job group by job title
                          job titles ranked highest to lowest by salary

               c.   Workforce Profile 3 (appendix 4):
                    Display of the workforce by organizational unit indicating the
                    administrator of each unit
                      within organizational unit by department
                       within department by job group
                          within job group by job title
                           job titles ranked highest to lowest by salary

               d.   Workforce Profile 4 (appendix 5):
                    Display of the workforce by organizational unit
                      within organizational unit by job group
                       within job group by job title
                          job titles ranked highest to lowest by salary

               e.   Workforce Profile 5 (appendix 6):
                    Display of the workforce by organizational unit
                      within organizational unit by department
                       within department by job group
                          within job group by job title
                           job titles ranked highest to lowest by salary




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     B.   Availability Analysis [41 CFR § 60-2.14] - Central Washington University conducts
          analyses to ascertain the percentages of minorities and women available for
          employment in each job group. To arrive at the availability rate for women and
          minorities, factors set forth by OFCCP are considered. This forms the standard
          measurement for determining the utilization of minorities and women in the
          workforce. Analyses comparing the workforce to the availability figures determine
          the existence of underutilization. Underutilization occurs when the employment
          rate of a protected group is lower than that group's availability; underutilization
          occurs when there is any difference in the rate. Utilization results are indicated on
          the Utilization Analysis and Goals Report (See appendix 8).

          1.   The university considers the percentage of minorities and women with
               requisite skills in the reasonable recruitment area when calculating availability
               for each job group. Internal candidates are included in the availability data for
               the reasonable recruitment area.

          2.   Reasonable recruitment area is drawn in such a way as to not have the effect
               of excluding minorities or women.

          3.   The university uses a three-step calculation to determine availability: First, the
               collection of quantified data ("raw statistics") for each factor (when possible);
               second, the "weight" of availability factors according to importance and
               proportional contribution to the overall job group; and third, the multiplication
               of raw statistical data by the value weights. The resulting sum provides the
               final estimate of availability for each job group.

          4.   Availability analysis is done separately for race/ethnicity, women, disability, age
               40 and over, and status as a disabled veteran or Vietnam era veteran.

           6. Availability resources for the three types of university employees and specific
              affected groups include:

               a.    Faculty (Job Groups 2A and 2B). Excellent data on degree conferral is
                     available. Availability is based on research conducted by the National
                     Opinion Research Center (NORC) with the support of the National
                     Science Foundation (NSF), the National Institutes of Health (NIH), the
                     National Endowment for the Humanities (NEH), the U.S. Department of
                     Education (USED), and the U.S. Department of Agriculture (USDA). Data
                     from 1997 through 2006 is combined by CWU by fine field for each
                     academic department.

               b.    Professional/Administrative positions. Availability for
                     professionals/administrators is calculated using two different sources:

                     1. 2000 U.S. Census data, available at
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                         http://www.census.gov/eeo2000/index.html for Washington State.

                     2. "2005-2006 Administrative Compensation Survey," College and
                        University Personnel Association for Human Resources; Table 36,
                        "Median Salaries of Males Compared to Females for Singe Incumbent
                        Positions – All Institutions," and Table 37, "Median Salaries of
                        Minorities Compared to Non-Minorities for Single Incumbent
                        Positions – All Institutions."

                c. Classified. Availability for classified staff personnel is calculated using 2000
                   U.S. Census data, available at http://www.census.gov/eeo2000/index.html
                   for Chelan, Grant, and Yakima Counties.

                d.   Vietnam era and disabled veterans. Availability for Vietnam era and
                     disabled veterans in the civilian labor force by detailed occupations
                     (2000 U.S. Census) is provided by the Washington State Department of
                     Personnel. Data is available only for Washington state.

                e.   Persons of disability. Availability for persons of disability is provided by
                     Washington State Department of Personnel, Higher Education Unit,
                     December 1996. This data began as national 1993 SIIP disability data and
                     was further analyzed by Department of Personnel staff for state-wide
                     use. A national availability percentage was provided for eight general
                     occupations.

                f.   Persons age 40 and over. Availability for persons age 40 and over in the
                     civilian labor force by detailed occupations (1990 U.S. Census) is provided
                     by GAAPCom's Availability Data Subcommittee, October 1997. Data is
                     available for Washington state, Yakima county, and Kittitas county.


V.   Establishment of Affirmative Action Employment Goals [41 CFR § 60-2.16] - Central
     Washington University establishes affirmative action employment goals and objectives.
     Employment goals are the most crucial element of the affirmative action plan because
     they guide affirmative action efforts during the coming year. Goals are flexible targets for
     hiring and promoting affected group members in job groups where underutilization
     exists. Goals are based upon utilization analyses and may be established for the following
     groups: American Indians/Alaskan Natives, Asians/Pacific Islanders, Blacks, Hispanics,
     women, persons with disabilities, persons age 40 and over, disabled veterans, and
     Vietnam era veterans. Goal reports are institution-wide.

     A.   Prior Year's Goals (See appendix 7, Goals Analysis Report)

          1.    For each job group and each affected group, the prior year's goals are
                reviewed in the goal analysis report that compares those goals to the hires and
                promotions made during the year.
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           2.    The comparison of the prior year's goals to hires and promotions are
                 completed institution-wide.

      B.   Current Year's Goals (See appendix 8)

           1.    For each job group, annual percentage goals, at least equal to availability, are
                 set for job groups where any underutilization exists.

           2.    In establishing goals, the university considers annual anticipated expansion,
                 reduction, and/or turnover rates within the workforce.

           3.    The university reports on current goals, and goals from the previous year.

           4.    Goals are established institution-wide for each job group.

VI.   Identification of Problem Areas [41 CFR § 60-2.17 (b)]

      A.   The university conducts in-depth analyses to identify problem areas and determine
           corrective action. These analyses and actions are specific to the institution based on
           its size, organizational structure, resources, and culture. Analyses include a
           narrative summary identifying underutilized affected groups and identification of
           the causes of underutilization and/or problem areas related to underutilization (see
           appendix 9). In-depth analyses of personnel practices may include review of:

           1.    Composition of the work force by affected group status;

           2.    Composition of applicant flow by affected group status, to determine whether
                 adverse impact occurs at the applicant stage, preliminary screening, interview
                 or hiring stages (see appendices 10 and 11 for applicant flow and impact ratio
                 analyses);

           3.    The selection process including position descriptions, position titles,
                 application forms, interview procedures, referral procedures, final selection
                 process, and similar factors;

           4.    Transfer and promotion practices;

           5.    Compensation systems to determine whether there are gender-, race-, or
                 ethnicity-based disparities.

      B.   Corrective action will be implemented if, after analysis, any of the following
           conditions are found:

           1.    Underutilization of affected groups is identified in specific job groups;

           2.    Lateral and/or vertical movement of affected groups is occurring at a lesser
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                rate than non-affected groups;

          3.    Selection processes are eliminating a significantly higher percentage of
                affected groups than non-affected groups;

          4.    Application and related pre-employment forms are not in compliance with
                Federal legislation;

          5.    Position descriptions inaccurately represent required duties;

          6.    Formal or scored selection procedures are not validated as required by the
                Office of Federal Contract Compliance Programs (OFCCP) Uniform Guidelines
                on Employee Selection [41 CFR § 60-3];

          7.   Test forms are not validated by location, work performance and inclusion of
                affected groups in the sample;

          8.   The referral ratio of affected groups to hiring supervisor or manager indicates a
                significantly higher percentage are being rejected as compared to non-
                affected group applicants;

          9.    Seniority provisions contribute to overt or inadvertent discrimination, (i.e., if a
                disparity exists by affected group status between length of service and types
                of jobs held);

          10. Equal opportunity or affirmative action policies are not fully supported by
              managers, supervisors or employees;

          11. Affected groups are underutilized or significantly underrepresented in training
              or career improvement programs;

          12. No formal techniques are established for evaluating effectiveness of the equal
              opportunity and affirmative action programs;

          13. Labor unions and vendors are not notified of their responsibilities;

          14. Purchase orders do not contain equal opportunity clause; and/or

          15. Affirmative action/equal employment posters are not on display.

VII. Development and Execution of Action-Oriented Programs - Central Washington University
     will develop action-oriented programs to correct identified problem areas. Programs will
     be results oriented and designed to eliminate problems and attain goals. Generally, such
     programs seek to increase the number of qualified affected group members to fill
     vacancies as they occur in underutilized areas.

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     A.   The university will review its utilization analyses to assist in developing appropriate
          action oriented programs.

     B.   The university will identify the person(s) responsible for each program or corrective
          action indicated.

     C.   The university will use currently available programs appropriate for higher
          education and state agencies.

     D.   Many of the following activities have been selected to address problem areas
          identified in appendix 9. (See appendix 12 for action oriented programs for the
          current plan year.)

          1.   Conduct detailed analyses of position descriptions to ensure that they
               accurately reflect position functions, and are consistent for the same positions
               from one location to another.

          2.   Analyze worker specifications at the division, department, location, and job
               title levels, using job performance criteria. Give special attention to ensure
               the requirements themselves do not constitute inadvertent discrimination.

          3.   Provide position announcements to recruitment sources, and to members of
               management and search committees involved in the recruiting, screening, and
               selection process.

          4.   Evaluate the total selection process to ensure freedom from bias and aid in
               the attainment of goals by:

               a.    Carefully selecting and training personnel involved in the recruiting,
                     screening, and selection;

               b.    Observing the requirements of the OFCCP Uniform Guidelines on
                     Employee Selection Procedures;

               c.    Analyzing procedures and eliminating those that are not objectively valid
                     including those selection techniques that may, when used improperly,
                     have the effect of discriminating against affected group members;

               d.    Requiring that search committees for administrative/professional and
                     faculty positions have female and minority representation; and

               e.    Providing availability information to hiring authorities and search
                     committees relevant to specific positions so that recruitment efforts and
                     applicant pools can be evaluated in relation to availability.

          5.   Consider the following techniques to improve recruitment and increase the
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                flow of affected group members:

                a.    Utilize the services of referral organizations and maintain contact with
                      community members prepared to refer applicants;

                b.    Encourage affected group employees to refer applicants;

                c.    Incorporate special recruiting efforts to reach affected group members at
                      all colleges and universities;

                d.    Include pictures of affected group employees on the university’s
                      employment website; and/or

                e.    Advertise for positions on a regular basis in news media aimed toward
                      members of affected groups; and/or, circulate position announcements
                      to higher education institutions, agencies, organizations and individuals
                      who serve affected group members.

           6.   Ensure that affected group employees are given equal opportunity for
                promotions, by using the following techniques:

                a.    Post or otherwise announce promotional opportunities;

                b.    Review position descriptions to ensure they are based on job-related
                      criteria, and assure that affected groups are not required to possess
                      higher qualifications than those of the lowest qualified incumbent;

                c.    Require supervisory personnel to submit written justification when
                      apparently qualified affected group applicants are passed over for
                      promotion;

                d.    Review union contracts to ensure that seniority practices and clauses are
                      nondiscriminatory and do not have a discriminatory effect.

VIII. Internal Audit and Reporting Systems - The office for equal opportunity collects and
      maintains data for affirmative action audit and reporting purposes. Such reports will be
      made available to federal and state for review purposes for a period of three years. The
      university's audit system is designed to monitor goal progress and analyze employment
      activity. The office for equal opportunity will:

     A.    Monitor records (using personnel action forms) of referrals, placements, transfers,
           promotions, and terminations at all levels to ensure that nondiscriminatory policy is
           carried out;

     B.    Prepare reports documenting the degree to which goals are attained;

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      C.   Review the report results with appropriate levels of management and department
           of human resources; and

      D.   Advise the president, provost, vice presidents, and/or board of trustees of program
           effectiveness and make recommendation to enhance performance.

IX.   Sex Discrimination Guidelines [41 CFR § 60-20] - Central Washington University ensures
      that policies and practices comply with the Sex Discrimination Guidelines, and states
      publicly that it is policy not to discriminate on the basis of sex.

      A.   The university will not discriminate in recruitment and advertisement [41 CFR § 60-
           20.2] and will:

           1.   Recruit employees of both genders for all jobs unless gender is a bona fide
                occupational qualification (BFOQ); and

           2.   Not express a gender preference in any advertisement for employment unless
                gender is a BFOQ.

      B.   The university will not discriminate in employment policies and practices [41 CFR §
           60-20.3] and will make the following assurances:

           1.   Equal opportunity policies expressly state that there is no discrimination
                against employees on the basis of gender. When dealing with bargaining
                representatives, the resulting agreements on conditions of employment will
                be consistent with these guidelines;

           2.   Employees of both genders have equal opportunity to any available job they
                are qualified to perform, unless gender is a BFOQ.

           3.   There is no distinction made based on gender regarding wages, hours, or other
                condition of employment. Contributions and resulting benefits in insurance,
                pensions and other benefits are the same for men and women.

           4.   There are no differences in treatment of men and women based on marital
                status. The university does not deny employment to women with young
                children unless the same exclusionary policies apply for men.

           5.   Policies and practices assure appropriate physical facilities to both genders.

           6.   Women are not denied the right to jobs they are qualified to perform based
                on any state "protective" law; such legislation restricts employment
                opportunities for men or women, and cannot be used as a basis for denying
                employment or establishing gender as a BFOQ;

           7.   Women are not penalized in conditions of employment because they require
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                time away from work on account of childbearing. When a woman employee
                qualifies for leave, childbearing is considered a justifiable leave of absence for
                a reasonable time. Further, the employee is reinstated to her original job or a
                position of like status and pay, without loss of permanent status;

          8.    No differences are specified for male and female employees on the basis of
                gender in retirement age; and

          9.    Differences in capabilities for job assignments among individuals are
                recognized, to the extent that distinctions are not based on gender.

     C.   The university makes no distinctions based on gender in seniority systems.

     D.   Pay schedules are not based on gender, and job classifications are not restricted by
          gender.

     E.   The university's affirmative action efforts include:

          1.    Encouraging women to apply for those jobs in categories in which they are
                traditionally underrepresented.

          2.    Including women in management skills training programs; and

          3.    Providing both genders equal access to training programs.


X.   Guidelines on Discrimination Because of Religion or National Origin [41 CFR § 60-50]
     Central Washington University adheres to the requirements of executive order 11246
     prohibiting discrimination on the basis of religion or national origin. The university
     assures the following:

     A.   Discrimination against applicants and employees because of religion or national
          origin, is prohibited; and

     B.   Religious observances and practices of applicants or employees are accommodated
          unless doing so presents an undue hardship on the conduct of the university's
          business. In determining undue hardship, the following factors are considered:
          business necessity, financial costs and expenses, and resulting personnel problems.




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    EQUAL OPPORTUNITY AND AFFIRMATIVE ACTION PROGRAMS FOR SPECIAL DISABLED
   VETERANS, VETERANS OF THE VIETNAM ERA, RECENTLY SEPARATED VETERANS, OTHER
                PROTECTED VETERANS AND PERSONS WITH DISABILITIES
                           [41 CFR § 60-250.1, § 60.741.5]

I. Equal Opportunity

   A. Policy [41 CFR § 60- 250.5(a), § 60-741.5(a)]

      The university does not discriminate against any employee or applicant for employment
      because he or she is a special disabled veteran, veteran of the Vietnam era, recently
      separated veteran, other protected veteran, or person of disability in regard to any
      position for which the employee or applicant for employment is qualified. The
      university takes affirmative action to employ, advance in employment, and otherwise
      treat qualified individuals without discrimination based on their status in one or more
      of the previously referenced groups.

   B. Contract Requirements [41 CFR § 60-250.4 (a), § 60-250.5, § 60-741.4 (a), § 60-741.5]

      The university will adhere to the following requirements:

      1. Include an equal opportunity clause in each covered government contract and
         subcontract in the amount of $25,000 or more; and

      2. Include an equal opportunity clause in all union agreements, review all contractual
         revisions to ensure they are nondiscriminatory, and discuss changes in practice
         related to applicable law in labor-management meetings and/or during labor
         negotiations.

   C. Nondiscrimination policies [41 § CFR 60-250.5, § 60-250.20, § 60-250.25, § 60-741.20, §
      60-741.25]

      Specific nondiscrimination provisions include, but are not limited to, the following
      personnel practices:

      1. Individuals are recruited, hired, trained and promoted in all job classifications based
         solely upon their qualifications and ability or potential ability to do the job.

      2. Principles of equal opportunity and affirmative action are the basis for fair
         employment decisions.

      3. Promotion decisions include only valid job related requirements and are in
         accordance with the principles of equal opportunity and affirmative action.


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       4. All personnel actions such as compensation, health benefits, insurance, layoffs,
          promotions, transfers, returns from layoffs, awards of tenure, fringe benefits,
          terminations and all university sponsored training, education, tuition exemptions,
          and social and recreational programs are administered without regard to an
          employee’s status as a special disabled veteran, Vietnam era veteran, recently
          separated veteran, other protected veteran or person of disability.

II. Affirmative Action Program [41 CFR, (b), (c), § 60-250.41, § 60-250.42, § 60-741.42]

   A. Program Requirements [41 CFR § 60-250.40 (a)]

       The office for equal opportunity annually reviews and updates the university’s
       affirmative action plan that sets forth policies, practices, data and procedures for
       special disabled veterans, veterans of the Vietnam era, recently separated veterans,
       other protected veterans, and persons with disabilities.

   B. Availability of Affirmative Action Plan [41 CFR § 60-250.41]

       The full affirmative action plan is available to any employee or applicant for
       employment for inspection upon request. Copies of the program are available on
       campus during business hours in office for equal opportunity and in the James E. Brooks
       Library Reference Section. Portions of the plan are also available online at
       http://www.cwu.edu/~oeo

  C.   Invitation to Self-Identify [41 CFR § 60-250.42, § 60-741.42]

       Applicants and employees who wish to benefit under this program may identify
       themselves by completing an applicant survey or personal data form). These forms
       state that the information is voluntarily provided and will be kept confidential, that
       refusal to provide it does not subject the applicant or employee to any adverse
       treatment, and that the information will be used only for affirmative action and equal
       opportunity purposes.

       In regard to reasonable accommodation, and in accordance with the Americans with
       Disabilities Act of 1990, an applicant may request accommodation in the application
       process, and an employee may request accommodation that will enable the employee
       to perform the essential functions of the position. In determining the appropriate
       accommodation, it may be necessary for a representative of the university to initiate an
       informal, interactive process with the individual with a disability to identify the
       limitations due to the disability and potential reasonable accommodation that could
       overcome those limitations.

       The university recognizes that an employee may advise the institution of the desire to
       benefit from the program at any time.


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  D. Development and Access To Policy Statement [41 CFR § 60-250.44, § 60-741.44]

       The university has developed and posted its equal opportunity policy statement. The
       policy is posted in the department of human resources, the office for equal opportunity,
       and on the office for equal opportunity (www.cwu.edu/~oeo). New employees receive
       a copy of the policy during orientation. The policy statement and affirmative action
       plan are also available at the James E. Brooks Library in the reference section.

  E.   Responsibility for Implementation [41 CFR § 60-250.6 (h), (1), § 60-741-44 (i)]

       Overall responsibility for implementation of the affirmative action program at Central
       Washington University rests with the president of the university, Jerilyn McIntyre. The
       president delegates responsibility to Staci Sleigh-Layman, interim director of the office
       for equal opportunity. The interim director of the office for equal opportunity is
       identified by name on all internal and external communications regarding the
       university’s equal opportunity and affirmative action policies and program. The director
       of disability support services, Rob Harden, is the designated Americans with Disabilities
       Act Coordinator.

       Members of university administration support the implementation of this program by:

       1. Adhering to university policies and procedures developed to promote affirmative
          action and equal opportunity; and,

       2. Discussing policies and procedures with their managers and supervisors to insure
          they understand their obligations.

       Employees placed through affirmative action efforts are protected from harassment
       under the equal employment policy.

  F.   Complaint Procedures [41 CFR § 60-250.61, § 60-741.61]

       The university's equal opportunity grievance procedures are consistent with the
       following requirements:

       1. Any applicant or employee may file, either internally or externally, a written
          complaint alleging a violation of their rights as protected under this affirmative
          action program. These procedures are provided at
          http://www.cwu.edu/~oeo/complaint_procedures.html

       2. All necessary steps are taken to ensure that no person intimidates, coerces, or
          discriminates against any person for the purpose of interfering with the filing of a
          complaint.

       3. Records regarding complaints and actions taken are maintained for a period of at
          least two years.
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      4. The university prohibits retaliation against any party for participation in the
         university’s complaint process.

  G. Review of Personnel Processes [CFR § 60-250.44 (b), § 60-271.144 (b)]

      1. Proper Consideration of Qualifications [CFR § 60-250.44 (b), § 60-271.144 (b)]

          The university provides for careful, thorough and systematic consideration of the
          job qualifications of applicants and employees who are known special disabled
          veterans, veterans of the Vietnam era, recently separated veterans, or other
          protected veterans for job vacancies filled either by hiring or promotion, and for all
          training opportunities offered or available. When necessary, procedures are
          modified or new procedures are designed to assure equal opportunity. Personnel
          processes do not stereotype special disabled veterans, veterans of the Vietnam era,
          recently separated veterans, other protected veterans or persons with disabilities.

      2. Physical and Mental Qualifications [CFR § 60-250.44 (c) (1), § 60-741.44 (c) (1), 29
         CFR § 1630.13]

          Central Washington University adheres to the following:

          a. Physical or mental job qualification requirements are subject to periodic review
             to ensure that, to the extent they screen out qualified disabled applicants or
             employees, they are job related and consistent with business necessity and the
             safe performance of the job.

          b. When physical or mental job qualification requirements are applied, to the
             extent the requirements tend to screen out qualified disabled applicants or
             employees, the requirements are related to the specific job and are consistent
             with business necessity and safe performance of the job.

          c. When a medical exam is required prior to employment, the results are used only
             in accordance with the affirmative action program and in compliance with the
             Americans with Disabilities Act. When inquiries into an applicant's or
             employee's physical or mental condition are made, or a medical examination is
             conducted, responses are kept confidential except for notification of the
             appropriate supervisor or manager regarding work restrictions and
             accommodation, of first aid and safety personnel regarding application of
             emergency treatment, and of government officials regarding compliance with
             federal law. As a matter of affirmative action, if an employee who is known to
             be a special disabled veteran is having significant difficulty performing his or her
             job and it is reasonable to conclude that the performance problem may be
             related to the known disability, the university shall confidentially notify the
             employee of the performance problem and inquire whether the problem is
             related to the employee’s disability. If the employee responds affirmatively, the
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               university will confidentially inquire whether the employee is in need of a
               reasonable accommodation.

  H. Reasonable Accommodation to Physical and Mental Limitations. [CFR § 60.250.44 (d), §
     741.44 (c) (1), 29 § 1630.13]

        1. Periodic reviews for physical or mental job qualifications are made to ensure that,
           to the extent they screen out qualified applicants or employees with disabilities,
           they are job related and consistent with business necessity and the safe
           performance of the job.

        2. Applicants for employment and promotion may be asked to demonstrate how, with
           or without reasonable accommodation, they will be able to perform job-related
           functions. They may not be asked questions about the nature, severity, or extent of
           their disability; illness or use of sick leave or any other questions that would elicit
           information about the presence or absence of a disability.

        3. Accommodation is determined on a case by case basis and is coordinated through
           disability support services. Reasonable accommodation will be provided unless the
           accommodation would impose an undue hardship on the operation of the
           university or the individual imposes a direct threat to the health and safety of the
           individual or others in the workplace. Such exceptions are documented, and only
           the President can deny a reasonable accommodation.

        4. Reasonable accommodation may include adjustments necessary to allow a person
           with a disability full participation in the workplace. Facilities are made readily
           accessible through improvements in buildings and grounds. Job restructuring, part-
           time or modified work schedules, acquisition or modification of equipment or
           assistive devices or the provision of readers or interpreters are available to
           employees when reasonable. Employees may also receive reasonable
           accommodation through leave of absence and sick leave. A shared leave program
           allows a classified or professional employee to donate accrued annual leave for
           another employee who, because of severe illness, disability or other condition,
           would otherwise have to take leave without pay.

   I.   Harassment [41 CFR § 60-540.44 (e), § 60-741.44 (e)]

        Policies are in place to protect employees from on the job harassment and/or
        discrimination based on disability or because of status as a special disabled veteran,
        Vietnam era veteran, recently separated veteran or other protected veteran. New
        employees are provided copies of the university’s nondiscrimination policy, and new
        employee orientations address the policy and avenues for filing complaints.




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   J. External dissemination of policy, outreach and positive recruitment [41 CFR § 60 250.44
      (f), § 60-741.44 (f), (g)]

      Central Washington University is committed to improving the employment
      opportunities of special disabled veterans, veterans of the Vietnam era, recently
      separated veterans, other protected veterans or persons with disabilities. The
      Washington state employment security offices, veterans organizations, and vocational
      rehabilitation organizations are notified of suitable job openings and are requested to
      recruit and refer qualified special disabled veterans, veterans of the Vietnam era,
      recently separated veterans, other protected veterans and persons with disabilities.
      The following outreach and recruitment activities may be implemented to assist the
      university in its affirmative action efforts:

      1. Internally communicate the affirmative action obligation to employ special disabled
         veterans, veterans of the Vietnam era, recently separated veterans, other protected
         veterans and persons with disabilities so as to foster understanding, acceptance,
         and support among executives, managers, supervisors, and all other employees, and
         to encourage them to aid the institution in meeting this obligation;

      2. Annually publish the policy statement in material used for recruitment of
         employees, informing all employees and prospective employees of its commitment
         to affirmative action for special disabled veterans, veterans of the Vietnam era,
         recently separated veterans, other protected veterans and persons with disabilities.
          All employment advertisements will include an equal opportunity and affirmative
         action statement;

      3. Enlist assistance and support of recruiting sources to recruit, and provide advice and
         technical assistance. Recruitment notices are sent to Washington state
         employment security offices, employment security veteran's services
         representatives, the veterans' administration, and the state vocational
         rehabilitation agency and other offices and agencies which serve the needs of
         special disabled veterans, veterans of the Vietnam era, recently separated veterans,
         other protected veterans and persons with disabilities.

      4. Subcontractors, vendors, and suppliers are notified of the university’s policy with a
         request for them to take appropriate action;

      5. Positions are posted openly, and all applicants are offered the opportunity to self
         identify as a disabled veteran, Vietnam era veteran, recently separated veteran,
         other protected veteran or persons of disability.

      6. Consider for employment all qualified special disabled veterans, veterans of the
         Vietnam era, recently separated veterans, other protected veterans and persons
         with disabilities not currently in the workforce, and who can be recruited through
         affirmative action efforts.

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      7. The university participates in work training programs with rehabilitation facilities and
          other community agencies and schools which specialize in on the job training or
          educating persons with disabilities.

   K. Internal Dissemination of Policy [41 CFR § 60-540.44 9 (g), § 60-741.44 (g)]

      Central Washington University disseminates its equal opportunity and affirmative action
      policies, in the following manner:

      1. The president of the university annually expresses her commitment to equal
         opportunity and affirmative action by either circulating a signed letter to all
         departments or through other forms of communication. In addition the policy
         (CWUP 2-2.1) is included in the university's policy manual which is available
         electronically on the university’s website (www.cwu.edu/~pres/policies/part2-
         2.2.pdf).

      2. The director of equal opportunity will publicize it on the university’s website
         continually, and each October in the university's newspaper, The Observer.

      3. The director of equal opportunity meets with members of the president's cabinet,
         management and supervisory personnel to explain the intent of the policy and
         individual responsibilities for effective implementation, reaffirming the president's
         affirmative action commitment.

      4. Members of the administration and supervisory personnel meet with their
         employees to discuss the policy and explain individual employee responsibilities at
         least annually.

      5. The office for equal opportunity, through new employee orientation (conducted by
         the department of human resources) and new faculty orientation (conducted by
         faculty relations) will ensure the distribution of the policy and discussion of the
         university's commitment to equal opportunity and affirmative action during
         orientations for new employees each year. The department of human resources will
         include a copy of the policy in all new employee packets on an ongoing basis.

      6. Union agreements reference the university’s nondiscrimination policy, and contract
         provisions are reviewed to ensure they are nondiscriminatory

      7. Vacancy announcements for civil service, exempt and faculty positions are on the
         university’s electronic job board and applications are submitted on-line.

      8. Articles on persons with disabilities are periodically featured in university
         publications and employees with disabilities are periodically included in
         publications.


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 X. Responsibility for Implementation [41 CFR § 60-540.44 9 (h), (i), § 60-741.44 (h), (i)]

      A. The overall responsibility for the effective implementation of the affirmative action
         program rests with the president of the university, who:

          1. Assigns operating responsibility for implementation of the program to
             administrators as appropriate.

          2. Provides the necessary top management support and staffing to the director of
             the office for equal opportunity to execute assigned duties within available
             funds.

          3. Reaffirms the university's commitment to affirmative action annually,
             disseminating this reaffirmation of the policy both internally and externally.

      B. The president has delegated specific authority and responsibility for the
         administration of the program to Staci Sleigh-Layman, interim director of the office
         for equal opportunity, who:

           1. Develops policy statements, affirmative action programs, and internal and
              external communication techniques, and has regular discussions with managers,
              supervisors, and employees to be certain institutional policies are being
              followed and employees placed through affirmative action efforts are not
              harassed;

           2. Identifies problem areas, implements affirmative action programs, and develops
              solutions;

           3. Designs and implements audit and reporting systems that:

              a. Measure the effectiveness of the institution's programs;

              b. Indicate need for remedial action;

              c. Determine the degree to which institutional goals are attained;

                  d. Determine whether employees who are known special disabled veterans,
                     veterans of the Vietnam era, recently separated veterans, or other
                     protected veterans and persons with disabilities have had the
                     opportunity to participate in all institution sponsored educational,
                     training, recreational, and social activities; and/or

           4. Serves as the official liaison between the institution and the OFCCP;

           5. Advises management of the latest developments in the affirmative action.
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