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Report Link OFCCP Issues Final Compensation Self-Evaluation Guidelines.Jackson Lewis LLP - July 25, 2006 Under federal affirmative action regulations, all covered federal contractors are required annually to perform an evaluation of compensation practices to ensure minorities and women are being fairly treated. Since inception, the published regulations, 41 CFR 60.2.17(b)(3), have been silent as to the methodology contractors should employ to analyze their workforces for pay equity purposes. On June 16, 2006 the Office of Federal Contract Compliance Programs published its final guidelines on performing compensation self evaluations, entitled "Voluntary Guidelines for Self Evaluation with Compensation Practices for Compliance with Non Discrimination Requirements of Executive Order 11246 With Respect to Systemic Compensation Discrimination". The Final Guidelines follow the November 16, 2004 proposed self-evaluation guidelines, which drew vigorous public comment. Report Link OFCCP Continues Its Aggressive Focus on Compensation Equity, Issuing New Standards for Finding Systemic Pay Discrimination and New Guidelines for Self-Evaluations.Hogan & Hartson LLP - July 13, 2006 The Office of Federal Contract Compliance Programs (OFCCP) is continuing its aggressive
focus on pay equity for minority and female employees of federal government contractors
or subcontractors (contractors). On June 16, 2006, OFCCP published formal interpretive
standards which the agency will follow in investigations and determinations concerning
whether a contractor engaged in systemic compensation discrimination. 71 FR 35124.
OFCCP collects compensation data from contractors during its compliance audits, and
contractors can face substantial back pay and other liability if OFCCP finds compensation
discrimination. On June 16, 2006, OFCCP also issued voluntary guidelines containing
options a contractor may follow to comply with its duty to conduct periodic self-evaluations
of its compensation practices. 71 FR 35114. The interpretive standards and voluntary
guidelines are summarized below. Report Link OFCCP Issues Final Standards and Employer Self Evaluation Guidelines Concerning Systemic Compensation Discrimination (pdf).Ogletree Deakins - June 26, 2006 OFCCP Issues Final Standards and Employer Self Evaluation Guidelines Concerning Systemic Compensation Discrimination. Report Link OFCCP Proposes "Companion Regulations" to EEOC's Proposed Guidance on Definition of "Applicant".Jackson Lewis LLP - April 07, 2004 In March 2004, after a wait of over three years, the EEOC published in the Federal Register a proposed inter-agency Guidance on the definition of applicant. Now the OFCCP has issued for public comment its own definition of "Internet Applicant."
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