UConn Health’s Affirmative Action Plan For Employment

Every year, in compliance with Connecticut General Statute (CGS) §46a-68, the Office of Institutional Equity (OIE) prepares the Affirmative Action Plan for Employment (Plan) for UConn Health.

The Plan is a comprehensive, results oriented continuing course of action, which articulates UConn Health’s strategy to combat discrimination, put forth a good faith effort to attain goals and achieve equal employment opportunity.  The objectives of the Plan are to establish goals which promote affirmative action and eliminate any policy or employment practice that adversely affects members of protected classes.

The Plan, which includes reports regarding UConn Health’s workforce as a whole and by occupational category, illustrates UConn Health’s goal to achieve a work force that is properly balanced and fully representational of the relevant labor market areas.  The Plan, both quantitatively and qualitatively, measures UConn Health’s degree of success in accomplishing hiring, promotion and program goals and evaluates the entire hiring process to ensure the absence of discriminatory policies and practices.

The Plan is submitted annually, by October 30, for review and approval by the Connecticut Commission on Human Rights and Opportunities (CHRO).  The Plan cannot be considered a “Plan” as defined by the statutes until it has been approved by the Commission.  The Plan must contain all 16 elements referenced in §46a-68 of the CGS, as amended by Section 12 of Public Act 83-569 and Section 1 of Public Act 84-41, and §46a-68-31 through 46a-68-74.

In addition to the required elements, a Plan will be approved only if (standard of review):

  • the work force, considered as a whole and by occupational category, is in parity with the relevant labor market area; or
  • the agency has met all or substantially all of its hiring, promotion and program goals; or
  • the agency has demonstrated every good faith effort to achieve such goals and despite these efforts has been unable to do so; and
  • the agency has substantially addressed deficiencies noted by the commission in prior plan reviews in accordance with Section 46a-68-62 (c).

Summary Objectives of the Plan  UConn Health’s history of approvals has been based on CHRO’s acceptance that UConn Health demonstrated every good faith effort to meet goals, rather than actual goal achievement.

If a Plan is not reviewed by CHRO within 90 days of the filing date, the Plan is deemed approved by default.

Questions regarding UConn Health’s Plan should be directed to a member of OIE by calling 860-679-3060.

Required Elements of the UConn Health’s Plan

Section 46a-68-78 Policy Statement: (Policy Statement 2016)
The Policy Statement describes UConn Health’s commitment to Affirmative Action and Equal Opportunity.  The Policy Statements included in the Affirmative Action Plan (Plan) are signed each year by the Chief Executive Office and Executive Vice President for Health Affairs.  OIE reviews them for potential changes prior to her signature.  The President’s Policy on Affirmative Action, the Policy Against Discrimination, Harassment, and Related Interpersonal Violence, and the Policy on People with Disabilities are distributed annually to all employees.  This section also contains all relevant state and federal laws that protect employees from discrimination

Section 46a-68-79 Internal Communication: (Internal Communication 2016)
Information in this section summarizes activities undertaken to communicate UConn Health’s commitment to Affirmative Action to the internal community.  UConn Health’s policy statements are publicized annually to all members of the community.  The full version of the Plan is available in The Office of Institutional Equity for review and comment.

Section 46a-68-80 External Communication and Recruitment Strategies:  (External Communication 2016)
This section details the various methods by which UConn Health publicizes its commitment to affirmative action to external constituencies.  These include, but are not limited to, employment recruiting sources, bidders, vendors, contractors, subcontractors, collective bargaining units which represent UConn Health employees, and others.  This section includes the Department of Purchasing annual report regarding contract compliance.

Section 46a-68-81 Assignment of Responsibility and Monitoring:  (Assignment of Responsibility 2016)
This section identifies the individuals and departments in UConn Health with duties and responsibilities, both wholly or in part, relating to promoting affirmative action policies and assuring compliance, including the development and implementation of the Plan.

Section 46a-68-82 Organizational Analysis:  (Organizational Analysis 2016)
Authorized position titles are grouped with other classifications having similar job content, salary ranges, and opportunity into occupational categories.  Within each job category, titles are ranked from the highest to lowest salary range.  The following categories, which correspond to federal designations for higher education institutions, are used throughout the Plan:

1 – Executive/Managerial
2 – Faculty
3 – Professional/Non-Faculty
4 – Secretarial/Clerical
5 – Technical/Paraprofessional
6 – Qualified Craft Worker
7-   Protective Services
7 – Maintenance/Service

Section 46a-68-83 Workforce Analysis: (Workforce Analysis 2016)
In this section, we summarize workforce data by race and gender, for all of UConn Health.  Separate summaries enumerate full-time and part-time employees.  Additional analyses report on age groupings and the number of employees with disabilities in the full-time workforce.

Section 46a-68-84 Availability Analysis: (Availability Analysis 2016)
As a preparatory step in determining whether protected classes are fully and fairly utilized in the work force, we conduct analysis to determine the availability of those groups in the labor markets relevant to each campus.  Separate analyses are conducted for each occupational category and for payroll titles with a significant number of employees at each location.  Various data sources such as employment statistics, unemployment data, racial and sexual compositions of persons in feeder groups, census data, and educational statistics are used to calculate the potential availability base, which is incorporated into the Utilization Analysis.  This section details the labor markets, data sources, and value weights used for each analysis group.

Section 46a-68-85 Utilization Analysis and Hiring and Promotion Goals:  (Utilization Analysis 2016)
In this section, we calculate how the representation of protected groups in UConn Health’s workforce compares to the availability of similar groups in the relevant labor market.  If the percentage of representation of a particular race/gender group in the workforce is less than the percentage of that group in the availability base, then a condition of underutilization exists.  These statistical comparisons provide the basis by which we set numerical hiring and promotional goals.  Utilization analyses are performed along the same lines as the various availability analyses, i.e., for each occupational category and for payroll titles with a significant number of employees at each campus.

Section 46a-68-86 Employment Analysis:  (Employment Analysis 2016)
UConn Health undertakes a comprehensive review of the employment process to identify policies and practices that perpetuate or build in barriers to equal employment opportunity.  In the Employment Process Analysis, using the same analysis groups as in the previous data sections, we report the various types of personnel actions which results in an increase or decrease in the specific analysis group during the Plan year.  These include hires; promotions; reassignments; separations; and others.  The Applicant Flow Analysis tracks applicants through the hiring or promotional process to identify the step at which they are no longer viable candidates.  Information on all training and personnel evaluations are also included in this section.

Section 46a-68-87 Identification of Problem Areas:  (Identification of Problem Areas 2016)
In this section, UConn Health reports on its examination of personnel policies and practices to identify non-quantifiable aspects of the employment process which may impede affirmative action progress.  Once again, we perform these analyses along the same lines as used in prior sections.  The following aspects of employment are addressed: employment applications, job qualifications, recruitment practices, personnel policies, job structuring, orientation, training, counseling, grievance procedure, evaluation, layoffs, and termination.  This section also includes adverse impact test information and results, which indicate potential problems with the employment process.  The adverse impact tests cover the areas of employment application, recruitment activities, performance evaluation, and termination.  Problems in these areas may impede or prevent the full and fair participation of members of protected groups.  Program goals are established to address and remedy potential adverse impact as indicted in this section.

Section 46a-68-88 Program Goals:  (Program Goals and Timetables 2016)
In this section, UConn Health establishes non-quantitative program goals which promote affirmative action and/or eliminate any policy or employment practice that adversely affects protected class members.  Program goals are mandated if the adverse impacts tests in the previous section indicate a significant impact to underrepresented groups in any of the employment process categories.  For each of these goals, we also set a target date for its accomplishment.

Section 46a-68-89 Discrimination Complaint Process:  (Discrimination Complaint Process 2016)
Each agency is required to establish procedures to process and resolve employee allegations of discrimination and harassment.  Any employee, student, or other member of the UConn Health community injured by the discriminatory behavior of an employee may file a complaint under the University’s Discrimination and Discriminatory Harassment Complaint Procedures UConn Health policy prohibits discrimination on the basis of age, ancestry, color, criminal record, genetic information, learning disability, marital status, past or present history of mental disability, mental retardation, national origin, physical disability, prior protected activity, race, religious creed, sex, sexual orientation, workplace hazards to the reproductive system, and any other group protected by civil rights laws.  Discrimination means unequal treatment or harassment based upon any of these group characteristics.

Section 46a-68-90 Goals Analysis:  (Goals Analysis 2016)
This section describes the various activities undertaken to achieve the hiring, promotion, upward mobility, and program goals contained in the previous year’s Plan.  In addition, UConn Health is required to provide clear, concise, and specific explanations for each permanent hire and promotion that occurred during the year.  These narrative explanations illustrate the University’s good faith effort.  The information collected in UConn Health’s search process is the primary source for the detailed descriptions required in this section.

Section 46a-68-91 Career Mobility:  (Upward Mobility and Staff Development 2016)
This section summarizes the year’s efforts and activities in providing upward mobility programming and opportunities.  While most upward mobility efforts are primarily directed toward employees in classified service, career counseling and exploring staff development opportunities are also ongoing for unclassified non-teaching professionals.

Section 46a-68-92 Good Faith Efforts: (Good Faith Efforts 2016)
This section summarizes UConn Health’s good faith efforts to promote equal opportunity to achieve a workplace that is free of discrimination; develop recruitment strategies that ensure opportunities for all qualified applicants, including underutilized groups; ensure a fair and non-discriminatory selection process; and provide career development opportunities to all interested and qualified employees.

Section 46a-68-93 Innovative Programs:  (Innovative Programs 2016)
In this section, the development and implementation of programs not covered elsewhere in the Plan contributing to affirmative action goals and diversity are explained.  Programs described in this section are innovative, comprehensive, and designed to create opportunities not otherwise available to achieve the full and fair participation of all protected group members.

Section 45-6a-68-94 Concluding Statement: (Concluding Statement 2016)
In this section, the Appointing Authority communicates his and UConn Health’s commitment to affirmative action and pledges to make every good faith effort to achieve the objectives set forth in the Plan.