The purpose of this work-in-progress research paper is to document the development of a coding process that can be used to critically examine the underlying assumptions and espoused approaches represented in diversity plans developed by administrators that signed the American Society of Engineering Education (ASEE) diversity pledge. In this paper, we report initial insight from developing a coding process for subsequently conducting a qualitative content analysis. We developed our coding process by reviewing a sample of engineering diversity plans (n=8) from institutions across the nation. Our future work will use this coding process to analyze a larger set of diversity, identify themes that can be used to improve efforts across the nation. This work is directly geared towards deans, department heads, faculty members, and other members of the engineering education community who should be responsible for improving diversity and inclusion in engineering.