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Topics: Compensation

New OFCCP Opinion Letter: Pay Analysis Groups

There's often confusion among federal contractors on how to properly identify and analyze their Pay Analysis Groups (PAG), leading to questions and a request for feedback from OFCCP. On July...

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OFCCP Will Not Use EEO-1 Pay Data in Audits

OFCCP formally announced in a federal register notice that it does not plan to request, accept, or use the Component 2 pay data collected by EEOC in the EEO-1 report....

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OFCCP Compliance Checks: A “Wolf in Sheep’s Clothing” Returns

The Trump Administration's Office of Federal Contract Compliance Programs (OFCCP) and its Director, Craig Leen, have recently resurrected the Compliance Check – what's known in some circles as a compliance...

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The “Road Trip” to Pay Data Reporting

A federal judge in Washington D.C. sent shockwaves through the employer community recently by reinstating a revised version of the EEO-1 report, which is now once again set to gather...

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“Ban the Box” Was Yesterday – Today It’s Salary History

The effort to combat gender pay inequity has taken many twists and turns at the federal level. We've all seen reports and data about the difference in average pay between...

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You Conducted a Pay Equity Analysis – Now What?

Author’s note: Pay equity and pay equity analyses are a complex and nuanced issue, and context matters. Employers should always consult with legal counsel prior to engaging in any proactive...

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OFCCP’s New Compensation Directive: The Good, the Bad, and the Analytics

The long-awaited, much anticipated new Directive on OFCCP's compensation analysis methodology has finally arrived … but for those contractors hoping for radical reform, the unfortunate news is there will be...

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Are Pay Secrecy Policies Another Necessary Casualty of the #MeToo Movement?

Over the last several decades, pay secrecy policies have persisted – and even thrived – in the American workplace. Employees who are told not to discuss their compensation with their...

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OFCCP and the Rule of Law – Part II: Pay Analysis Groups

In my initial article, published on November 17, 2017, I proposed an evaluation of OFCCP's recent regulatory and enforcement positions through the lenses of the fundamental and perennial question, "What...

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