The Office of Federal Contract Compliance Programs issued an Advance Notice of Proposed Rulemaking on August 10, 2011, seeking input on a new “Compensation Data Collection Tool” that would replace the discontinued EO Survey. According to the Notice, the OFCCP is considering adopting some new practices that will substantially increase the burdens that employers who are federal contractors face. Among other things, the OFCCP is:

-“Exploring the possibility” of using the data collected “to identify opportunities for nationwide multi-establishment compensation reviews.”

-Considering requiring companies to submit compensation information as part of the bidding process for federal contracts.

The OFCCP says that it may use the tool to identify establishments for compensation audits and “to identify and analyze industry trends, Federal contractors’ compensation practices and potential equal employment-related issues.”