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ARTICLE · 15 DECEMBER 2004

OFCCP Proposes New Rules For Evaluating Pay Discrimination And Contractor Self-Audits

DLA Piper Rudnick Gray Cary
Explore more from DLA Piper Rudnick Gray Cary

The Office of Federal Contract Compliance Programs (OFCCP) has recently published two proposed guidelines which, if made final, will significantly change the landscape for evaluating whether the compensation practices of government contractors comply with Executive Order 11246.

United StatesEmployment and HR
Richard Hafets
Richard Hafets
Adrianne Mazura
Adrianne Mazura

The Office of Federal Contract Compliance Programs (OFCCP) has recently published two proposed guidelines which, if made final, will significantly change the landscape for evaluating whether the compensation practices of government contractors comply with Executive Order 11246. The first proposal, Interpreting Nondiscrimination Requirements of Executive Order 11246, is intended to plainly set out the OFCCP’s official standards regarding systemic compensation discrimination. The second proposal, Guidelines for Self-Evaluation, is intended to provide contractors with practical assistance in developing their own self-audits.

Significantly, these new proposals do away with the previously used, and much maligned, pay grade theory. The OFCCP will now apply a statistical analysis to "Similarly Situated Employee Groupings."

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