July 17, 2019

July 17, 2019

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July 16, 2019

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July 15, 2019

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BREAKING NEWS: OFCCP Issues New Compensation Directive and Other Directives

It’s here!  OFCCP has finally issued its long-awaited, much-anticipated, new compensation directive.  The Directive explicitly replaces the controversial Directive 307 and sets out the Agency’s current approach, and commitment to transparency, with respect to pay equity analyses.

Directive 2018-05: Analysis of Contractor Compensation Practices During a Compliance Evaluation outlines “standard procedures for reviewing contractor compensation practices during a compliance evaluation.”  The eight-page Directive explains the agency’s methodology for creating Pay Analysis Groups, details its statistical methodology and modeling, including a listing of the variables it will control for in its regression models.  The Directive also sets out OFCCP’s process for providing contractors with information regarding its conclusions.

OFCCP also released two additional directives, Directive 2018-06: Contractor Recognition Program and Directive 2018-07: Affirmative Action Program Verification Initiative.

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About this Author

Laura Mitchell, Jackson Lewis, Management Representation lawyer, Contractual Drafting Attorney
Principal

Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and government contractor compliance.

Ms. Mitchell is a Principal in the firm’s Affirmative Action and OFCCP Defense practice group, representing government and non-government contractors in Office of Federal Contract Compliance Programs (OFCCP) matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming...

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