View all Articles

Affirmative Action Employers: Are You Complying With OFCCP’s Pay Equity Directive?

As a reminder, the OFCCP issued a compensation Directive (DIR) 2022-01 in 2022 requiring Federal Contractors and Subcontractors to conduct a compensation analysis as part of their annual Affirmative Action Program

In OFCCP audits Federal Contractors will now be required to provide documentation proving they have conducted the appropriate compensation analyses. 

OFCCP will Focus on the Following Areas:​​​

  • Pay disparities or other evidence of potential pay discrimination among similarly situated employees based on race, ethnicity, and/or gender.
  •  Employee complaints of pay discrimination or other anecdotal evidence of discrimination.​​​​​
  •  Inconsistencies in how you are applying pay policies.​​​​​​
  •  Statistical analyses or other evidence that a protected group of workers (gender, race, ethnicity) is disproportionately concentrated in lower-paying positions or pay levels within a position.

HR Works has developed a checklist to assist Affirmative Action Employers with meeting the requirements of this directive.



Contact HR Works to learn about our comprehensive Affirmative Action Services, and how HR Works can help you take the necessary steps to comply with OFCCP’s compensation Directive.

HR Works, headquartered in upstate New York, is a human resource management outsourcing and consulting firm serving clients throughout the United States for over thirty years. HR Works provides scalable strategic human resource management and consulting services, including: affirmative action programs; benefits administration outsourcing; HRIS self-service technology; full-time, part-time and interim on-site HR managers; HR audits; legally reviewed employee handbooks and supervisor manuals; talent management and recruiting services; and training of managers and HR professionals.