Many things have been written and debated in 2014 about the OFCCP’s (Office of Federal Contract Compliance Programs) renewed interest in the “theory of steering” that the agency re-introduced in Directive 307. While the OFCCP critics have accepted that the theory of steering is adequate for selection claims, they continue to consider its application to compensation claims as inappropriate at best. Nevertheless, the OFCCP was successful and effective in its use of this theory in compensation cases against federal contractors.

The steering theory fits perfectly well with the OFCCP current pay gap reduction agenda. The overall pay gap between men and women (at the societal level) is believed to be substantially affected by the differential in pay among different jobs with different levels of concentration of men and women (men