In the first internal agency directive during Jenny Yang's
tenure as director, the Office of Federal Contract Compliance
Programs (OFCCP) issued Directive
2022-01, entitled “Pay Equity Audits” on March 15,
2022.
OFCCP's directive informs contractors that the regulatory
requirement in 41 C.F.R. Section 60-2.17(b) to “perform
in-depth analyses of … [c]ompensation systems to determine
whether there are gender-, race-, or ethnicity-based
disparities” requires annual quantitative “pay equity
audits.” The agency goes further in claiming that
“contractor transparency” requires that contractors
provide these pay equity audits to OFCCP upon request.
Highlights of Directive 2022-01 include the following:
