Morgan Lewis

OFCCP Publishes Final Standards on Systemic Compensation Discrimination and Voluntary Compensation Self-Audit Guidelines

By Labor and Employment

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LawFlash/Client Alert

  • published on:

    06/16/2006

In June 16, 2006's Federal Register, OFCCP published final standards on systemic compensation discrimination, as well as final guidelines for voluntary self audits of compensation practices.

The final systemic discrimination standards outline the techniques OFCCP will use to evaluate contractors’ pay practices during a compliance review. The final self-audit guidelines encourage contractors to self audit their pay practices through recommended self-audit methods. Both the final standards and final guidelines retain the major components of the proposed standards and guidelines, including the focus on comparisons of only “similarly situated” employees and the use of multiple regression analyses. In addition, OFCCP provided several important clarifications and modifications in response to contractors’ comments on the proposed standards and guidelines.

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