"The OFCCP\'s New Compliance Developments"

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OFCCP - EEO Compliance Information (December 2012)

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"The OFCCP\'s New Compliance Developments"

  1. 1. The OFCCP’s New Compliance DevelopmentsFocuses  Compensation disparities (fair pay)  Employment of veterans and individuals with disabilitiesRespond to Audit Letter  Keep record once letter is received  30 days to submit information to respondAdverse Impact  Minority vs. Non-Minority  Individual Race Groups vs. Whites  Favored vs. Non-Favored (Groups AA vs. Whites, etc.)*Perform salary equity analysis and be able to defend disparities Pending Law“New Scheduling Letter”Policies  FMLA  Pregnancy Leave  Accommodations – Religious ObservancesMore Specific Demographic Information  Total each minority sub-group (rather than all minorities)  Data both job groups and job titleMore Specific Compensation(February 1st Annually)  All employees (FT/PT/Temp./Contractors/Etc.  Gender/Race & Ethnicity Information (hire date and job group)  Other compensation (adjustments and salary)  Any documentation related to compensation practicesVETS 100-A & EEO-1(3 Year Retention Records)Statistical Significance  Significant differences in compensation  Two standard deviations 5% difference  Difference of two standard deviations or more are statistically significant  Rare outcome
  2. 2. The OFCCP’s New Compliance DevelopmentsMultiple Regression Analysis  Employees differ  Multiple regression examines differences in average pay controlling for other factors • Comparisons are within job groupings • Control for differences in experience, etc.Compensation Audits  2% “smell test” – identify differences in job title/sub groups  Submit follow-up data  Regression analysis by job title  “Individual” compensation claims vs. systematic claims  Disparity (Job Group/Title/Pay Grade) Proposed Laws  Proposed regulations regarding Veterans (placement goals)  Proposed regulations regarding individuals with disabilities (placement goal – stringent placement & accommodation(s).)  Compensation collection tool

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