"The OFCCP\'s New Compliance Developments"
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
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