September 15 through October 15 marks the observance of National Hispanic Heritage Month in the United States. Influenced by the civil rights movements during the 1960s and the desire to increase inclusion and appreciation of multicultural identities within the United States, this month-long celebration of the Hispanic started in Continue Reading...
OFCCP Releases Major Revisions to Pay Equity Audit Procedures in Directive 2022-01 Revision 1
Shortly after the release of Directive 2022-01 back in March, 2022, alarm bells and outcries rang out that the “OFCCP is coming for your privileged pay equity audits!!”. As BCGi’s Matt Nusbaum noted in his post, the OFCCP does not get to sidestep the longstanding precedent of attorney-client privilege. This revision settles the issue once and for Continue Reading...
The OFCCP Wants to See Your “Pay Equity” Analyses (Directive 2022-01)
The OFCCP has gone all-in with their new compensation directive announcing that the agency intends to request, and expects to receive without pushback, contractors’ “pay equity audits” prepared in response to 41 C.F.R. § 60-2.17(b)(3) “[i]f the desk audit reveals disparities in pay or other concerns about the contractor’s compensation Continue Reading...
OFCCP Quietly Reverses Policy on EEO-1 Component 2 Data
The Office of Federal Contract Compliance Programs (OFCCP) has published a notice in the Federal Register that the agency is reversing its position regarding EEO-1 “Component 2” compensation data. The OFCCP is announcing that the agency will now analyze the data to see if it can be used to “inform” enforcement and compliance efforts and/or to Continue Reading...
Compensation Analysis Sections Added to BCGi Encyclopedia
In an effort to help our members and the general public better understand the complex world of compensation analyses for the purposes of nondiscrimination and pay equity, we are adding updated sections from “Compensation Analysis: A Practitioner’s Guide to Identifying and Addressing Compensation Disparities,” by Patrick Nooren and Dan Continue Reading...
