[IPAC-List] When does a test become a test...
RICHARD.TONOWSKI at EEOC.GOV
Thu Feb 17 13:23:41 EST 2011
As you say, the general rule is that if it's a selection procedure, it's a test. So in an EEO situation, there will be matters of adverse impact and validity, as pertinent to what the test is.
A way to handle the "where to draw the line " on the need for formal validation efforts was implemented at the Postal service some years ago. The procedures have been superceded, but the principles may still apply. Essentially, anything except application review and interviewing was off-limits to the non-psychologists. There was training and reference material developed for how to do app review and behaviorally-based interviewing. Anyone who had a role in the selection process as a selecting official or a review (interviewing) committee member had to be trained; this was enforced by HR. The KSAs for the jobs, which would guide the app review and interview, were available in a data base. Local management could modify, but there were rules, guidance, and training on that also.
I tracked what was happening with the system from 1989 to 1999 and I know of no serious EEO issues.
The psychologists were available for help on request. This did not happen often, and usually when it did it was on modifying postings for more tailored KSAs for generic titles and figuring out how to assess them. The only modification that I can recall was the addition in some cases of writing samples. They had an option for simulations, but that probably wasn't used except by an HR director who knew how to do them.
This system was intended for managerial and professional jobs. There were selection systems involving "real" tests for the clerical, skilled trades, and core (e.g., Letter Carrier) jobs and separate guidance on interviewing for suitability. First-level supervisor had a modified app and interview process and also a basic skills test (reading, writing, and arithmetic), Assessment centers were used at the executive level.
The EEO situation was undoubtedly helped by applicant pools being small and internal, although the system also was used for external recruitment with large applicant pools.
I think key points in doing something like this are working closely on system development with the managers who will have to use it, keeping the lawyers in the loop so that defensibility concerns are addressed in the design (you need to make decisions on record-keeping responsibilities), having good training, making training and re-training easily accessible (USPS went from classroom to on-demand video), and having clear expectations among all the stakeholders (applicants, those involved in the selection process, HR that monitors, senior management that makes sure it happens as it should) as to what the process is and what should or shouldn't happen in it. The latter helps to make the system self-enforcing; everybody knows what's supposed to happen, so deviations will be noticed and questioned.
Disclaimer: This is not intended as legal advice, or policy interpretation regarding EEOC. For those interested, the way to get policy advice is to ask your local EEOC office or ask for a private letter from EEOC's Office of Legal Counsel in D.C.
Richard F. Tonowski, Ph.D., SPHR
Office of General Counsel/Research and Analytic Services
U.S. Equal Employment Opportunity Commission
131 M Street NE Room 5NW20S
Washington DC 20507-0001
Voice: (202) 663-4752
Fax: (202) 663-4196
E-mail: richard.tonowski at eeoc.gov
>>> "Reindl, Kevin" <KReindl at semprautilities.com> 2/17/2011 12:15 PM >>>
Since most of the subscribers to this list likely oversee the policies related to testing/validation in their organizations, I thought this might be a good place to get other's thoughts on an issue that I have been struggling with for quite some time.
I know that legal/professional guidelines consider any selection procedure as open to scrutiny in terms of job relatedness/validity, and our company policy states that any "test" that is used for selection in our company must be validated [by our research group] according to acceptable legal/professional guidelines. In our organization, however, we tend to draw a line (albeit not a very clear line) between what our I/O folks should "validate" and what should be left to hiring managers/recruiters/staffing professionals. For example, if someone wanted to implement a cognitive ability test to screen out applicants for a high-volume entry level position, we would definitely conduct a validity study to ensure the test is job related, predictive and defensible. On the other hand, while we provide advice and a process, we leave interview questions up to our staffing professionals/hiring managers to decide.
My struggle is that we have some staffing professionals and hiring managers who request our "validation services" for every selection procedure (including specific interview questions, etc.), but at the same time others folks will develop tests that should obviously have some validity documentation (e.g., a scored job simulation that is given during an interview process) and will avoid the "red tape" of having to go through more formal validation. With only a couple I/O's involved in selection here, we really don't have the resources to take on all of the requests we receive...so...
My question is this: At what point, or under what circumstances do you undergo validation and documentation related to the validity of a selection procedure in your organization? What criteria do you use to draw that line (e.g., is it structured/scored, does it result in a pass/fail, will it likely result in adverse impact, will it be used for large-volume jobs, etc.)?
Senior Human Resources Research & Analysis Advisor
San Diego Gas & Electric
8306 Century Park Court, CP41A
San Diego, CA 92123-1530
Email: kreindl at semprautilities.com<mailto:kreindl at semprautilities.com>
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