Pay equity is front and center as a priority for the White House and the Office of Federal Contract Compliance Programs (“OFCCP”). In August the Federal Register published a notice of proposed rulemaking (“NPRM”) that would require most Federal contractors and first-tier subcontractors to submit compensation data to the OFCCP through a web-based filing system on an annual basis. This compensation data tool—dubbed the “Equal Pay Report”—was responsive to the April 8, 2014, Presidential Memorandum signed by President Obama that called for proposed regulations to be published within 120 days. The NPRM provides for a 90-day public comment period ending November 6. Your comments will be important; please consider contributing your concerns to OFCCP by that date.

The impact of the Equal Pay Report on federal contractors will be significant. OFCCP has stated that it will use the compensation data to create industry compensation