OFCCP Pay Equity Directive Overview

OFCCP Directive 2022-01 Rev 1  Advancing Pay Equity Through Compensation Analysis, clarifies that contractors are now required to maintain and make available documentation of their annual compensation analysis.

HR Works has put together an overview of these new requirements impacting Federal Contractors in the video below.

Quick Takeaways:

  • OFCCP maintained its stance that employers should be conducting an annual compensation analysis, and that the agency has the authority to access and review documentation of that compensation analysis.
  • Where the analysis reveals problem areas, OFCCP also expects employers to produce documented action-oriented programs designed to address problem areas.
  • OFCCP has taken the stance that the most useful form of documentation they can review is the contractor’s own compensation analysis.
  • Employers may face negative publicity and employee relations issues inherent in any assumption or accusation of discriminatory pay practices or non-compliance with employment regulations.
  • HR Works’ core, comprehensive Affirmative Action Services already provide a fully compliant Affirmative Action Plan (AAP). In addition to maintaining a written AAP, employers must also ensure they are conducting and documenting a compensation analysis in accordance with Directive 2022-01.
  • HR Works now offers additional compensation services to support Federal Contractors with conducting an OFCCP compensation analysis and complying with this Directive.

Is Your Affirmative Action Program Compliant?

  • Does your written plan include both narrative and statistical components?
  • If you receive an audit letter today, can you respond with a compliant AAP within 30 days?
  • Can you prove that you’ve recently recruited through sources that target women, minorities, veterans and individuals with disabilities?
  • Has your management team been trained on the results of your AAP, which is no more than 12 months old?
  • Have you conducted and documented an annual compensation analysis?