ARTICLE · 26 JULY 2019

OFCCP Issues Opinion Letter On Whether Pre-Approved Pay Analysis Groupings Will Be Accepted In Future Audits

Littler Mendelson

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On July 22, 2019, the Office of Federal Contract Compliance Programs (OFCCP) issued its second Opinion Letter since November 30, 2018, when Directive 2019-03

United StatesGovernment, Public Sector

Littler Mendelson, P.C.

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On July 22, 2019, the Office of Federal Contract Compliance Programs (OFCCP) issued its second Opinion Letter since November 30, 2018, when Directive 2019-03 announced the agency's intent to begin delivering such guidance to the contractor community. OFCCP's July 22 Opinion Letter provides guidance as to whether contractors can collaborate with the agency to develop Pay Analysis Groupings (PAG) that OFCCP would then accept as valid for use in future compliance evaluations.

In the Opinion Letter, OFCCP acknowledged that the agency's latest guidance on compensation evaluations, Directive 2018-05, provides contractors with the opportunity to submit their PAG structure to OFCCP for review and feedback, which the agency would "take into account" in future compliance evaluations. For this purpose, OFCCP reminded contractors that submission of PAGs for agency approval must include sufficient data for it to determine if the aggregation is similar to what would be available

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