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ARTICLE · 21 SEPTEMBER 2018

OFCCP Issues New Compensation Directive

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner

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The OFCCP's recent Directive, issued on August 24, 2018, signals a move towards greater transparency in the compensation review process for contractors.

United StatesEmployment and HR
Marilyn M. Fish
Marilyn M. Fish
Alison Elena Loy
Alison Elena Loy

The OFCCP's recent Directive, issued on August 24, 2018, signals a move towards greater transparency in the compensation review process for contractors. With this new Directive, the OFCCP has rescinded former Obama-era guidance on compensation review, for a more open and transparent process. The OFCCP sent out 750 corporate scheduling announcement letters to contractors on September 7, 2018, so compliance reviews may be imminent for a number of employers.

Highlights

Pay Analysis Groupings

The Directive sets out the OFCCP's procedures for grouping similarly-situated employees for statistical compensation analysis. The OFCCP explains that it analyzes compensation for similarly-situated employees by:

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