Harvard's Affirmative Action Plan

(The following is a copy of a letter sent to President Pusey from John G. Bynoe. Regional Director for the Office for Civil Rights, finding unacceptable Harvard's initial Affirmative Action Plan.)

Dr. Nathan M. Pusey

President

Harvard University

Cambridge, Massachusetts 02138

Dear President Pusey:

We regret to inform you that the Affirmative Action Plan submitted November 2, 1970, is unacceptable. The purpose of an Affirmative Action Plan is to set forth specific and result-oriented procedures to which your institution commits itself to apply every good-faith effort. The objectives of these procedures plus such effort is equal employment opportunity. Procedures without effort to make them work are meaningless; and effort, undirected by specific and meaningful procedures, is inadequate. An acceptable Affirmative Action Plan must include an analysis of the areas within which the contractor is deficient in the utilization of minorities and women and, further, must state goals and timetables to which your good-faith effort must be directed in order to correct the deficiencies.

Several members of our staff have reviewed your Affirmative Action Plan and have found it deficient in the above-mentioned areas.

The Affirmative Action Plans of individual departments with the possible exception of one are not in keeping with the attitudes displayed by department chairmen or their representatives. In each meeting held with department chairmen or their representatives, a concerted effort was made to explain what is required of each contractor and what constitutes a good Affirmative Action Plan. Each department chairman or his representative stated that he understood these requirements. However, the plan submitted does not constitute an acceptable Affirmative Action Plan.

Mr. Robert L. Albert, Chief, Contract Compliance Branch in this Office, and other members of this staff are available to you and your staff for any technical assistance and advice that may be needed to formulate an acceptable Affirmative Action Plan.

Sincerely yours,

John G. Bynoe

Regional Civil Rights Director

Office for Civil Rights

(The following is a partial text of the Harvard Affirmative Action Plan. The plan was submitted by Harvard on February 5, 1971 and accepted by HEW on February ll. The original plan, submitted by Harvard on November 2, 1970, was rejected by HEW on the grounds that it did not include specific goals and timetables for the correction of deficiencies in minority and female hiring.)

V. PROBLEM AREAS

Harvard University's policy of non-discrimination has not meant a significant increase in the minority representation among its employees. Recently developed audit procedures show an underutilization of minority and female personnel in many areas of University employment.

Lack of minority representation is most readily identifiable in the categories of Craftsmen; Teaching personnel, especially tenured faculty; and administrative officials and managers at the policy-making level.

The absence of women among the teaching faculties is also pointed up in the recent audit of University employment performance.

A. Personnel Procedures

1) Until very recently, the University had not developed a system that would record and monitor the sources, numbers, and rejection rates of minority persons who applied at the Central Personnel Office. As such, the University had no reliable means of making a proper analysis of its minority recruitment needs; could not routinely monitor the hiring practices of the department within the University, and had no systematic means of inquiring into reasons for rejection of minority applicants or terminations.

2) A University-wide Salary and Wage Analysis was instituted in September 1969 and the expected completion-implementation date is June 30, 1971. Until the present, there was no comprehensive wage schedule in use, and this gave rise to wage discrepancies for the same work done in different areas of the University. In addition, the Salary and Wage Analysis program has regularized the job specifications and requirements which will eliminate the unevenness of work experience and-or education among persons with the same job and salary classification.

B. Minority Representation in Academic Positions

Harvard University has only a small representation of minority group persons in academic positions. This situation is due, in part, to the lack of vigorous recruiting efforts to locate minorities, as well as the lack of an effective equal employment opportunity monitoring program.

C. Women in Academic Positions

There are many areas of the University that have no, or very few women in academic positions.

Instances of lower compensation for women among the faculties, cited by HEW, are still being investigated. Our amended affirmative action plan will incorporate the findings at the conclusion of the investigation.

In the meantime, a number of actions and policies have been undertaken to seek out and employ more women in the academic ranks, as well as to increase participation by women on committees which involve recruitment and selection of academicians. Moreover, steps have been taken to increase the participation by women on policy-making committees and the committees which deal with the treatment of both academic and non-academic employees.

VI. ISSUES RAISED IN HEW LETTER OF DECEMBER 31, 1970

1. Improve ratio of female employment in academic positions.

Harvard University recognizes that women are underrepresented in academic positions and commits itself to hiring additional women for such positions. As mentioned below, the complete picture re: Corporation Appointment-level needs will not become clear until later this Spring. The presence of committees to advise on the increased utilization of women in a number of the faculties should result in a number of recommendations that will facilitate the implementation of this University policy. The specific actions projected for the next twelve months are included in the individual faculty tables which are attached.

A significant corollary action in some faculties is the concerted attempt to recruit advanced degree female candidates in order to increase the population of women in that particular discipline or profession.

2. Female Participation and Employment in Ph.D. Programs.

Harvard University does not have admissions policies and practices which result in the discriminatory treatment of women. We, too, feel that to construe employment opportunity within some Ph.D. programs as being within the meaning of the Executive Orders does raise certain policy questions. Not the least of these is whether the significant criterion for admissions is the proportion or percentage of the applicant pool by sex.

Harvard University agrees to respond to the policy position articulated by the Secretary and any further findings applicable to Harvard.

3. Increase the participation of women on committees which involve the recruitment and selection of academicians, etc.

As already noted, women have been placed on such committees, with a University commitment to appoint women to additional committees as their number increases among the faculties. Among the specifics are:

a. Appointment of women to search committees for tenured positions.

b. Insure involvement of women in selection process of non-tenured positions.

c. Report to Dean of all applicants considered, as well as specific reasons why any women considered were not finally selected, if that be the case.

d. Review of all employees to eliminate any salary and-or promotional inequalities which might exist as a result of sex.

e. Appointment of women to policy-making committees.

f. Appointment of women to committees that deal with academic and non-academic employees.

4. Achieve salary equality between current male and female employees in every job category.

We have already made mention of the University-wide salary program which was implemented in the Fall of 1969. This program will assure that Harvard employees doing comparable work are paid within the same appropriate salary range.

This program applies only to nonexempt clerical and technical employees, and does not include some 400 "S & W" "professional, executive, or administrative" employees who are exempt from the overtime requirements of the Federal Fair Labor Standards Act. A separate program will be designed for these employees at a later date.

5. Compensate through the payment of back wages each female employee who has lost wages due to discriminatory treatment by the University.

The review of data relative to the specifics cited in your letter of December 31, 1970 has not been completed. If findings warrant such, we will file an attachment to our Affirmative Action Program to correct and eliminate such deficiencies.

6. Assure that female applicants for non-academic employment receive consideration for employment commensurate with their classifications. Assure that the concept of male and female job classification is eliminated through the recruitment, placement, transfer, and promotion of male and female applicants and employees into occupations from which they have traditionally been excluded.

The University does not classify positions by sex, and assures equal consideration to all applicants for employment. The University will seek to identify qualifications for each applicant which best meet the requirements for each job opening. Job requirements will be carefully reviewed to determine that non-essential elements are eliminated. This review is being conducted by the Personnel Office in conjunction with representatives from each faculty.

VII. ANTICIPATED PERSONNEL NEEDS

In the face of budgetary restrictions, it does not appear likely that the University work force will be increased significantly. In order to maintain the present strength, taking into account the annual turn-over rate, we anticipate that 2500 S & W employees will be hired during the next year by the University. Although the turn-over rate for 1970 was 43 per cent, the latter months of the year reveal a drop in that rate which we expect will continue. Accordingly, we anticipate the number of new hires to drop from last year's figure of 2800 to 2500.

It presents a much more difficult task to try to determine the number of corporation appointments which will be open for the next academic year. However, drawing on the experience of the past two years, we estimate that 1000 will be hired by August 31, 1971.

VIII. OBJECTIVES

Of the 2500 S & W employees that the University anticipates hiring by August 31, 1971, we expect to have 170 of these new hires of minority backgrounds.

The picture regarding Corporation Appointments will not become very clear until later in the Spring. However, on the basis of the partially-complete data at present, the University commits itself to hiring at least 58 additional female Corporation Appointees by August 31, 1971, for the 1971-72 academic year.

IX. AUDIT

The University has established a monitoring system to audit our progress in implementation of Affirmative Action Programs. The Personnel Office will prepare on a quarterly basis reports reflecting the current employment profile. The Office for Minority Affairs will provide analysis of such reports, including progress toward goals in relation to target dates on a University-wide and departmental basis. Those analysis will be distributed to appropriate officers throughout the University in order to show the current University performance re: Affirmative Action.

Inherent in these reports is the understanding that the target numbers or goals are set to measure in part the University's good faith intentions and performance toward equal employment opportunity. There is no attempt, explicit or implicit, to operate on a racially-based quota system.

X. COMMUNITY RELATIONS

Harvard University will continue to cooperate and to work with other governmental agencies and community groups, as well as national minority organizations which have equal employment opportunity objectives for the purpose of developing significant means to remove overt and covert barriers to equal opportunity for minority groups and women.

XI. TECHNICAL REQUIREMENTS

1) Contractors and Subcontractors

All contractors and subcontractors have been notified of the University's responsibilities under Executive Orders 11246 and 11375 and their ensuing obligations. The University will notify all contractors and subcontractors of amendments to the Executive Order, and will alter all contracts and purchase orders to reflect such changes.

2) Purchase Orders

All purchase orders carry Equal Employment Opportunity clauses, with specific intent that statutes outlined in this clause shall be adhered to by vendors. The University, in accordance with law, requires additional stipulations for purchase orders issued under government contracts or grants to which suppliers are required to adhere.

3) Advertising

Selection for an participation in University employment is without regard to race, age, sex, color, religion, political affiliation, national origin or ancestry. The phrase "an equal opportunity employer" will continue to be used as a reflection of this practice. The use of minority news media will also continue to be used as part of our advertising practice. (See Appendix D).

4) Facilities

The University certifies that all facilities will continue to be maintained on a non-segregated basis; certification of non-segregated facilities is also required of contractors.

5) Equal Employment Posters

The University will continue to display, in conspicuous locations normally trafficked by employees and applicants for employment, official equal employment opportunity posters.

6) Annual Compliance Report

The University has submitted annually since 1963 the EEO-1 Compliance Report, and will continue to do so.

7) Validation of Tests

The only examination required of applicants are typing tests; they are administered without regard for race, sex, age, color, religion, political affiliation, national origin or ancestry.

XII. INVENTORY OF UNIVERSITY EFFORTS IN EQUAL OPPORTUNITY

1) MA-5 Training Program--In March of 1970, Harvard received a subsequently implemented Manpower Act V Contract from the Labor Department. Ms. Vivian Ingersoll is the Program Director. The Program provides for the training of new employees in entry-level jobs.

Option B of the Contract provides for the up-grading of 23 present employees. Trainees receive instruction in English and Mathematics, on-the-job training, typing lessons and counselling.

2) Apprentice Program--The Apprenticeship Program in skilled trades is administered by a joint Management-Union Committee; the provisions of this program were negotiated in December 1969 through a collective bargaining agreement.

The program, operated through the Department of Buildings and Grounds currently has 50 apprentices and 2 mechanic trainees. Twenty-two of these participants are Minority employees.

3) Summer Youth Employment Programs--The University was involved in two programs this past Summer. Twenty-two Cambridge youths, 50 per cent of whom are of Minority background, worked at the University during June, July and August. The program was underwritten by the University.

The Cambridge Economic Opportunity Council coordinated the Federally financed Youth Corps project. Twenty Cambridge youths worked at Harvard for half-day sessions and participated in typing courses during the afternoon at another location. Twenty-five per cent of this group were from Minority groups.

4) Instruction in English--Harvard began a program last Spring, under the direction of Mr. Lloyd David, to employ non-English speaking Puerto-Ricans in the Departments of Buildings and Grounds and Food Services, and to provide daily instruction in English.

5) Upward Bound--Harvard Upward Bound staff has as its goals to be of assistance to students enabling them to graduate from high school and to provide support in the application process for post-secondary schools.

The most important aspect of this program has been the academic year follow-up, which reinforces the more dynamic programs of the Summer sessions. The follow-up phase in-

Selection for and participation in University employment is without regard to race, age, sex, color, religion, political affiliation, national origin or ancestry. volves placement of seniors, tutoring and topical seminars.

6) Participation of Women in Teaching & Administration-- Two committees to explore ways of increasing women's participation in teaching and administrative capacities began their work last Spring. One committee is from the Graduate School of Education; the other from the Faculty of Arts and Sciences.

The charge to both committees has been to review existing policies and to make recommendations for such alterations as necessary to increase the role of women in all aspects of employment within the University. Public hearings began October 23. Final reports and recommendations from both committees are expected later this year.

7) EEO Construction Offices and Construction Contracts-- In December of 1969, Harvard appointed Clifford L. Alexander, Jr. as Consultant to the Corporation for Equal Employment Opportunity. As a result of his efforts, contracts were negotiated with clauses assuring equal employment opportunities for minority workers.

In addition, the University will award, whenever possible, subcontracts to minority firms. Such contracts have already been awarded for work on Gund Hall, Rockefeller Hall, and the Music building. Also, contracts for renovation at the Business School, Medical School and Memorial Hall have been awarded to minority firms.

Finally, the University has promoted joint ventures between white construction firms and black construction firms. (Two such ventures are under intensive consideration now).

To monitor the effective implementation of these construction contracts, the University appointed Mr. William A. Lee who serves as EEO Construction Officer. Mr. Lee assumed his duties during the summer months, and has developed a systematic reporting system to monitor implementation of minority employment clauses on construction sites.

8) Institute for Educational Management-- During the Summer of 1970 the first session of the Institute for Educational Management was held at the Harvard Business School. Specific Foundation grants were sought and received to provide support for minority administrators applying for the program, and also to assure participation in this program.

9) Faculty Audit Program--In the Summer of 1968, Harvard, Columbia and Yale Universities began a joint venture to invite faculty members from predominantly Negro Colleges for discussions and classes at each University during the summer months. Over 50 teachers participated in the summer sessions. The teachers receive free room, board, tuition, travel and personal expenses for the eight week program.

Twenty-five of the fifty visiting teachers came to Harvard.

10) Graduate Student Recruiter-- In response to the need for generating greater numbers of potential applicants from minority communities, the Dean of the Graduate School of Arts and Sciences appointed Mr. George Strickland to serve as a representative for the Graduate School. Mr. Strickland has been responsible for identifying potential candidates for doctoral programs, visiting predominantly black schools which have not previously sent applicants to Harvard and working with departments in their search for minority applicants.

In addition, the Graduate School of Arts and Sciences has increased the number of graduate fellowships designated specifically for minority candidates so that no student who is accepted will be faced with inadequate financial support.

11) Minority Recruiter--The Personnel Office appointed Miss Valeria Jones in the Spring of 1970 to serve as community recruiter. She spends the majority of her time in the field contacting agencies and individuals in the Boston-Cambridge area. She is constantly advised of current job openings and the requirements for these jobs as they are listed with Employment.

In addition, Miss Jones works closely with our interviewers in Employment to keep apprised of the progress of minority applicants who have sought jobs with the University.

In addition, Miss Jones works closely with our interviewers in Employment to keep apprised of the progress on minority applicants who have sought with the University.

12) AAEO--In the Fall of 1969, Mr. Charles Price and Mr. Charles Hamilton developed Afro-Americans for Educational Opportunity. The AAEO is a program designed to identify qualified minority applicants, and to make those applicants known to Universities participating in the Program. AAEO operates under a grant from the Carnegie Foundation, and has offices in Holyoke Center at Harvard.

Both Mr. Price and Mr. Hamilton hold Corporation Appointments