Compliance with Section 503 and VEVRAA: Still Required
Recent changes in federal regulations regarding affirmative action have left many employers wondering what is going on with their other federal...
3 min read
Alex Gonzalez
:
Mar 15, 2022 4:43:30 PM
Contractors may have to provide OFCCP with a complete copy of their pay equity audits
On Equal Pay Day, March 15th, the Office of Federal Contracts Compliance Programs released Directive 2022-01: Pay Equity Audits. The directive “explains how OFCCP reviews contractors’ compliance with their obligations to conduct in-depth compensation analysis under 41 CFR 60-2.17(b)(3).”
Key Points
The directive supersedes any previous agency guidance, including procedures outlined in the Federal Contractor Compliance Manual (FCCM).
OFCCP is “committed to removing barriers to opportunity, including pay discrimination and occupational segregation, which are key drivers of persistent pay disparities. In addition, hiring barriers, steering, assignment patterns, and occupational segregation all contribute to systemic pay disparities. Women are overrepresented in low-paid jobs that often lack critical benefits and are underrepresented in high-paying jobs.”
According to EEOC Chair Charlotte A. Burrows, Equal Pay Day “symbolizes how far into the year women must work to earn what men earned the year before. Women who work full-time in the United State make just 83 cents for every dollar paid to men. The pay gap is even wider for women of color, mothers of young children, and women with disabilities. Due to pay inequality, women stand to lose approximately $407,760 over the course of a 40-year career.”
In the fiscal year 2021, the EEOC advanced pay equity by resolving significant compensation discrimination cases during the administrative process, including:
On Equal Pay Day, we will continue to emphasize the importance of reviewing compensation systems to ensure pay equity. It is important to collect and maintain compensation-related data which is critical in producing a meaningful Pay Equity Analysis. Directive 2022-01 does not tell you how to conduct your pay equity audits but does inform us what we can expect on the compensation side during a compliance evaluation. Neither OFCCP nor EEOC are taking the issue of pay equity lightly and are vigorously enforcing the regulations to target employers who are unfairly paying employees.
Let OutSolve assist you by conducting a compensation risk analysis to identify pay problems before either of these agencies do. Contact your OutSolve Consultant or OutSolve directly at 888-414-2410 or by email at info@outsolve.com.
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