On March 15, 2022, the Office of Federal Contract Compliance Programs (“OFCCP”) issued a Directive[1] addressing federal contractors’ obligations to analyze their compensation systems for impediments to equal employment opportunity and to turn over such analyses when under audit.[2]
[1] Directive 2022-01, https://www.dol.gov/agencies/ofccp/directives/2022-01
[2] As part of their affirmative action obligations, the OFCCP requires federal contractors are required to perform an in-depth analysis of their total employment practices to determine whether and where impediments to equal employment opportunity exist, including conducting an in-depth analysis of their compensation systems to determine whether there are gender-, race-, or ethnicity-based disparities, as provided in 41 CFR 60-2.17(b)(3).3.
Read More