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Equal Pay Reporting Requirements Federal Contractors

Cozen O'Connor

FAR Council Withdraws Proposed Rule on Federal Contractor Pay Requests

Cozen O'Connor on

On January 8, 2025, the Federal Acquisition Regulatory (FAR) Council withdrew its Proposed Rule on Pay Equity and Transparency in Federal Contracting (the proposed rule), which was initially introduced in January 2024. This...more

MoFo Employment Law Commentary (ELC)

FAR Council Withdraws “Pay Equity and Transparency” Proposed Rule

On January 8, 2025, the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulation (FAR) Council withdrew a proposed rule that would have banned federal contractors and subcontractors from seeking or...more

Seyfarth Shaw LLP

2021 EEO-1 Reports of Federal Contractors to be Released by OFCCP Absent Employer Action

Seyfarth Shaw LLP on

The University of Utah and a non-profit organization named "As You Sow" have issued FOIA requests to the Office of Federal Contract Compliance Programs (“OFCCP”) for the 2021 Type 2 Consolidated EEO-1 Reports filed by federal...more

Polsinelli

To Disclose or Not to Disclose: OFCCP to Appeal Adverse EEO-1 Report Disclosure Order

Polsinelli on

As previously reported, in late December 2023, the Northern District of California ordered OFCCP to release the EEO-1 reports of federal contractors it had previously withheld from production based on various exemptions under...more

FordHarrison

California Pay Data Reporting and Pay Transparency for Federal Contractors

FordHarrison on

Executive Summary: This Alert discusses actions at the state and federal level to require transparency in pay, in an effort to address pay equity issues. Employers should be aware of new and existing requirements and ensure...more

FordHarrison

Federal Court Orders OFCCP to Release Federal Contractors' EEO-1 Reports

FordHarrison on

Executive Summary: On December 22, 2023, a federal court in California ordered the OFCCP to release the EEO-1 reports of federal contractors who had filed an objection to the agency’s release of their EEO-1 data in response...more

Littler

OFCCP Again Extends Deadline for Submitting Objections to EEO-1 Disclosure, But New Wrinkles Added

Littler on

On February 14, 2023, OFCCP announced that it was again extending the deadline for employers to file objections to the disclosure of their EEO-1 data in response to a FOIA request from the Center for Investigative Reporting....more

MoFo Employment Law Commentary (ELC)

OFCCP Extends Deadline To Object To FOIA Request For EEO-1 Reports

On September 15, 2022, OFCCP announced that it is extending the September 19, 2022 deadline for contractors to object to Type 2 EEO-1 Reports in response to the Freedom of Information Act (FOIA) request by the Center for...more

Polsinelli

I Object! – OFCCP Extends Deadline to October 19 to Submit Objections to FOIA Request for All Type 2 Consolidated EEO-1 Reports

Polsinelli on

Yesterday OFCCP announced that it is extending the deadline to respond to and submit objections pursuant to its August 19, 2022, Notice in the Federal Register regarding a Freedom of Information Act (“FOIA”) request from Will...more

Littler

OFCCP Extends Deadline for Objecting to Proposed Disclosures of EEO-1 Data

Littler on

As outlined in our August 22 Insight, OFCCP announced an intention to produce federal contractors’ Type 2 EEO-1 data in response to a FOIA request from the Center for Investigative Reporting (CIR).  Employers were given until...more

Stinson - Government Contracting Matters

OFCCP Revises Directive on Pay Equity Audits / Compensation Analysis

On August 18, 2022, the Office of Federal Contract Compliance Programs (“OFCCP”) issued “Advancing Pay Equity Through Compensation Analysis,” a revision to Directive 2022-01, “Pay Edit Audits.” The revised Directive states...more

FordHarrison

OFCCP Receives Media Request for EEO-1, Type 2 Report Filed by Federal Contractors

FordHarrison on

On August 19, the Federal Register published a Notice that OFCCP received a request under the Freedom of Information Act (FOIA) from the Center for Investigative Reporting (CIR). CIR is seeking all federal prime contractors’...more

FordHarrison

OFCCP Issues New Pay Equity Directive

FordHarrison on

On March 15, 2022, the Office of Federal Contract Compliance Programs (OFCCP) issued a new Directive clarifying covered contractors’ obligation to conduct pay equity audits on an annual basis. Quite notably, the OFCCP issued...more

Orrick, Herrington & Sutcliffe LLP

OFCCP Reverses Course: Actually, Let’s See Those EEO‐1 Pay Data Reports

This month, OFCCP officially rescinded a Notice from nearly two years ago, which stated that it would not “request, accept, or use Component 2 data” that the EEOC collected with the 2017 and 2018 EEO-1 reports....more

Polsinelli

OFCCP May Use EEO-1 Data Reported By Employers in Support of Enforcement Efforts

Polsinelli on

On September 1, 2021, the Office of Federal Contract Compliance Programs (OFCCP) announced that it would “evaluate” using compensation data reported by federal contractors in annual EEO-1 filings to guide its enforcement...more

Stinson - Government Contracting Matters

Contractors Should Prepare for Increased OFCCP Pay Scrutiny

With the change in administration, government contractors should anticipate increased scrutiny of their pay practices. President Biden signaled heightened pay equity enforcement on his first day in office by appointing Jenny...more

Stinson - Government Contracting Matters

Updates on EEO-1 Reports, Non-Binary Self-Identification, and VETS-4212 Reports

EEO-1 Reports - With September upon us, many employers are remembering the prior filing deadline for EEO-1 Reports and wondering what is happening with that obligation. The short answer is that the U.S. Equal Employment...more

Fisher Phillips

July 2020: The Top 17 Labor And Employment Law Stories

Fisher Phillips on

It’s hard to keep up with all the recent changes to labor and employment law. While the law always seems to evolve at a rapid pace, there have been an unprecedented number of changes for the past few years—and this past month...more

Stinson - Government Contracting Matters

End to EEO-1 Component 2 Pay Data Reporting for Now…

On February 10, 2020, in National Women’s Law Center v. Office of Management and Budget, the U.S. District Court for the District of Columbia ordered the Equal Employment Opportunity Commission’s (EEOC’s) collection of gender...more

Orrick - Equal Pay Pulse

OFCCP Says “No Thanks” to EEOC’s EEO-1 Pay Data

As you’ll recall from our extensive coverage of the EEO-1 pay data collection saga (which we previously reported on here, here, here, here, here, here, here, here, and here), private employers, including federal contractors,...more

Littler

OFCCP Will Not Request, Accept or Use EEO-1 Component 2 Data

Littler on

The Office of Federal Contract Compliance Programs (OFCCP) has announced that it will not request, accept, or use “Component 2” compensation data submitted on the EEO-1 form....more

Proskauer - Law and the Workplace

EEO-1 Component 2 Reports Are Still Due September 30, But….

Employers have been furiously working to prepare their EEO-1 Component 2 submissions by the September 30 deadline.  Some employers who underestimated the task have asked us whether the EEOC’s submission portal will remain...more

Polsinelli

EEO-1 Update: Judge Orders Pay Data Component To Be Filed By September 30

Polsinelli on

On April 25, 2019, the U.S. District Court for the District of Columbia gave an oral ruling from the bench reportedly accepting the EEOC’s proposal to make employers submit their 2018 pay data by September 30, 2019....more

Proskauer - Law and the Workplace

EEO-1 Update: More Wait and See

Yesterday, US District Judge Tanya Chutkan held a hearing on the pay data component of the EEO-1 form (“Component 2”). In March, Judge Chutkan lifted the stay on collection of Component 2 data that had been imposed by the...more

Foley & Lardner LLP

EEO-1 Report – Will Employers Need to Include Compensation Data or Not?

Foley & Lardner LLP on

...Generally, employers with 100 or more employees, and certain federal contractors and subcontractors, are required to file an Employer Information Report EEO-1 each year. The EEO-1 is a report of the employer’s work force...more

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