[IPAC-List] FW: EEOC "Discussion" Letter

Pritchard, Ken Ken.Pritchard at MWAA.com
Tue Dec 6 14:31:31 EST 2011

-----Original Message-----
From: Pritchard, Ken
Sent: Tuesday, December 06, 2011 2:30 PM
To: 'Mitch Stein'; 'ipac-list at ipacweb.org'
Subject: RE: [IPAC-List] EEOC "Discussion" Letter

My own view of this is that employers should carefully consider what it
is that a HS diploma represents so as to determine why "equivalent
education, experience and training" could, or could not, be substituted
for the "hard" educational criteria, and then be able to specify (for
its own use) many of the sets of acceptable substitution and apply both
the "hard" criteria and the sets of substitution in the review of
applications. (This is true of many other "hard" educational criteria,
in my view, except those established by licensing boards and such. Why
NOT permit substitutions for education for most types and levels of

Of course, a vacancy posting should indicate that "an equivalent
combination of education, experience and training" is acceptable. I
would not try to publish for applicants ALL of the exact sets of
substitutable human capital that the employer has pre-identified because
my guess is that many times the employer only "knows it when it sees

Here's a provocative question: Does anyone doubt that, GENERALLY, a HS
diploma of 20 or 30 years ago represents much more than one does today?

- Ken Pritchard, Metro Wash Airports Authority

-----Original Message-----
From: ipac-list-bounces at ipacweb.org
[mailto:ipac-list-bounces at ipacweb.org] On Behalf Of Mitch Stein
Sent: Tuesday, December 06, 2011 1:00 PM
To: 'ipac-list at ipacweb.org'
Subject: [IPAC-List] EEOC "Discussion" Letter

Spotted this in the employment law news.


On the one hand, I agree with the legal interpretation in the letter.
On the other hand, I wonder if this creates an impossible burden on
employers with huge numbers of applicants?

Something not discussed in the letter: if accepting a GED or job related
experience in lieu of education avoids the need to do individual
assessments of everyone who claims they did not get a diploma because of
LD or some other disability. If I were an ambulance-chasing shyster I'd
be out recruiting every high school dropout who might arguably have some
LD I could get to start flooding organizations with applications for
every job that required high school education or higher.


Mitchell Stein, PhD
Director of Research
TN Dept. of Human Resources
(615) 532-8069

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