The OFCCP’s New Compensation Directive: A Lot Below the Surface – JD Supra – DC Initiative on Racial Equity
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[author: Paul McGovern]

The Office of Federal Contract Compliance Programs’ (OFCCP) new Directive 2022-01, concerning federal contractors’ “obligation to conduct in-depth compensation analysis,” raises issues that will take time to sort out.

The Directive seeks to define federal contractors’ obligations for pay equity self-review under 41 CFR 60-2.17(b)(3), the ‘supply and service’ regulation outlining the gender-, race-, and ethnicity-based affirmative action obligations they must satisfy.

41 CFR 60-2.17(b)(3) states that “the contractor must perform in-depth analyses of its total employment process” (emphasis added).  However, 41 CFR 60-2.17(b)(3) does not define how to meet the requirement.  It simply states that “at a minimum the contractor must evaluate compensation system(s) to determine whether there are gender-, race-, or ethnicity-based disparities.”

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