OFCCP Directive on Internal Pay Equity Audits Takes on Privilege Claims – JD Supra – DC Initiative on Racial Equity
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Federal contractors who conduct pay equity audits under attorney-client and work product privileges face increased risks under a new directive by the U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP). On March 15, 2022, OFCCP issued Directive 2022-1 stating that under certain circumstances, its compliance officers have the authority to seek pay equity audits conducted by federal contractors even if those audits were conducted pursuant to well-established privileges. While this directive is subregulatory guidance and does not have the effect of a regulation, it follows the rigorous tactics noted in this previous update.

About Directive 2022-1

The starting point for understanding Directive 2022-1 is the regulatory language at 41 CFR 60-2.17(b). In pertinent part, this regulation requires contactors to “evaluate [


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