Discrimination cases are essentially “games” of making relevant, suitable, or valid comparisons between suitable, valid, or appropriate comparator(s). While anti-discrimination laws do not define discrimination in a comparative sense, comparators...
When the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) begins an affirmative action compliance review, it sends the organization subject to the review a letter that...
IntroductionIn a time of changing laws and a pervasive fear of OFCCP audits, it is always a good idea to make sure that people have a good understanding of the...
In the previous part of this article (Part I), I reviewed some of the enforcement data the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has made...
On January 30, 2015, the Office of Federal Contract Compliance Programs (“OFCCP”) published its proposed rule regarding updates to the current guidelines governing discrimination on the basis of sex. According...
In our last two posts, we examined key actions taken by the OFCCP in 2014 through the lens of President Obama’s ambitious agenda. While some OFCCP actions have reflected Mr....
In Part I of this post we examined the close connection between the OFCCP’s focus on pay equity and the hiring of veterans and individuals with disabilities (IWDs) in 2014...
The key to surviving a compliance review, or audit, is in preparing the AAP—way before the scheduling letter is received. Remember, a compliance review focuses on the activity from the...
The “unknown problem” is actually very familiar to anyone who analyzes applicant data. So, it’s not really “unknown” at all. But the problem is much broader than one might imagine,...
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