News & Analysis as of

Office of Federal Contract Compliance Programs Wage and Hour Compensation & Benefits

K&L Gates LLP

Proposed Rule by the Federal Acquisition Regulatory Council Would Ban the Use of Salary History Data by Federal Contractors and...

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UPDATE: On 8 January 2025, the Federal Acquisition Regulatory Council (FAR Council) officially withdrew its proposed rule that would have (1) barred federal contractors from seeking and using job applicants’ compensation...more

Berkshire

Compensation in the New Administration – Mainstays and New Directions in Investigations

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A change in presidential administrations can influence federal enforcement agencies’ priorities, how they interpret laws and guidelines, and how they carry out enforcement. Consequently, the transition to the Trump...more

Dorsey & Whitney LLP

Do You Know What to Pay Your Work Force? New Decision Invalidates the Federal Contractor Minimum Wage Rule

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Employers with Federal contracts have experienced unique challenges in the past few years—from navigating the Federal contractor vaccine mandate to new rules related to sick leave and time off. One of the most significant...more

CDF Labor Law LLP

OFCCP Revises Directive on Federal Contractors’ Compliance with “Pay Equity Audits”

CDF Labor Law LLP on

On March 15, 2022, the Office of Federal Contract Compliance Programs (“OFCCP”) issued a Directive regarding OFCCP’s expectations of compliance with the regulatory provisions of 41 CFR 60-2.17(b)(3). The regulations require...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

Littler

OFCCP Revises Compensation Analysis Directive But Leaves Questions About Documentation Created Under Attorney-Client Privilege

Littler on

On August 18, 2022, the Office of Federal Contract Compliance Programs (OFCCP) issued a revised version of its Directive 2022-01 - Advancing Pay Equity Through Compensation Analysis, which was originally issued on March 15,...more

Jones Day

New Directive From OFCCP Signals the Biden Administration's Prioritization of Pay Equity

Jones Day on

On March 15, 2022, to coincide with this year's "Equal Pay Day," the OFCCP issued a new Directive on pay equity audits. Its stated purpose is to "provide guidance on how OFCCP will evaluate federal contractors' compliance...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

Proskauer - Government Contractor Compliance...

OFCCP Will Start Demanding Contractors’ Internal Pay Equity Audits

On March 15, 2022, the OFCCP issued its first directive since President Biden took office. Directive 2022-01 (the “Directive”) addresses contractors’ obligations to analyze their compensation systems and to turn over such...more

Polsinelli

OFCCP/NILG Compensation Roundtable Highlights Contractors’ Concerns with OFCCP’s Compensation Evaluations

Polsinelli on

The frank discussion during the roundtable highlighted contractors’ ongoing concerns regarding OFCCP’s approach to the evaluation of the compensation of small groups of specialized employees and smaller AAP groups....more

Jackson Lewis P.C.

Highlights From The OFCCP And NILG Compensation Roundtable

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On Tuesday, February 18, 2020 the National Industry Liaison Group (“NILG”) and the Office of Federal Contract Compliance Programs (“OFCCP”) held a Compensation Roundtable at the US. Department of Labor in Washington D.C. ...more

Hogan Lovells

Pay Equity: Still a Growing Concern

Hogan Lovells on

Pay equity continues to be a complex and evolving issue for employers. Although the Equal Employment Opportunity Commission (“EEOC”) recently ended its Component 2 pay data collection, employers still face substantial...more

Seyfarth Shaw LLP

Seyfarth Policy Matters Newsletter - December 2019

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WHD Rulemakings Full Speed Ahead. This is a busy time for the Wage & Hour Division’s regulatory agenda. Early in the week, the White House approved its final rule updating the regular rate regulations. The updates are...more

Polsinelli

OFCCP Announces Three Multimillion Dollar Bias Settlements

Polsinelli on

The OFCCP opened the month of October by announcing three multimillion dollar settlements with major government contractors.  The agency entered into early resolution conciliation agreements with Goldman Sachs & Co. LLC and...more

Polsinelli

OFCCP Opinion Letter Endorses Pre-Approval of PAGs

Polsinelli on

In a welcome development for federal government contractors, OFCCP issued its second opinion letter on July 22, 2019.  The opinion letter endorsed a process through which contractors can submit proposed pay analysis groups...more

Seyfarth Shaw LLP

Google: Demonstrating The Hazards Of Employment Discrimination From Every Angle

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Seyfarth Synopsis: Google’s recent travails with simultaneous traditional and “reverse” discrimination claims signal a new era of dynamic employment discrimination risk. Employers will be wise to consider the push and pull...more

Constangy, Brooks, Smith & Prophete, LLP

OFCCP’s Broad Request For Comp Data Denied

An ALJ has largely put the kibosh on a request for decades of comp data. In January 2017, the Office of Federal Contract Compliance Programs filed an administrative complaint against Oracle America, Inc., alleging systemic...more

Seyfarth Shaw LLP

OFCCP Takes Aim at Oracle’s Hiring and Compensation Practices

Seyfarth Shaw LLP on

Seyfarth Synopsis: On January 22, 2019, the Office of Federal Contract Compliance Programs (“OFCCP” or “the Agency”) filed a motion for leave to file a new amended complaint in connection with its 2017 Compliance Evaluation...more

Stinson LLP

Are You Ready for an OFCCP Compensation Audit?

Stinson LLP on

The Office of Federal Contract Compliance Programs (OFCCP) recently issued Directive 2018-05, a compensation-related directive that OFCCP touts as part of its effort to be more transparent to government contractors. ...more

Jackson Lewis P.C.

OFCCP’s New Compensation Directive – What Does It Really Mean For Contractors?

Jackson Lewis P.C. on

There’s been a lot of discussion in past days about OFCCP’s new Compensation Directive, which describes the Agency’s approach to investigating pay discrimination. We’ve spent some time digging into the details of the...more

Orrick, Herrington & Sutcliffe LLP

Change Of Course? OFCCP Issues Long-Awaited Revised Compensation Guidelines

In a highly anticipated move, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) issued its new compensation directive on August 24, 2018. ...more

Littler

Something Old, Something New: Contractor Recognition and AAP Verification on the Horizon at OFCCP

Littler on

On August 24, 2018, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) issued three new directives, 2018-05, 2018-06, and 2018-07. While directive 2018-05 has received most of the attention...more

Littler

OFCCP Reins in Compensation Analysis by Rescinding Directive 307 and Issuing New Guidance

Littler on

On August 24, 2018, the Office of Federal Contract Compliance Programs (OFCCP) rescinded Directive 307 and its Obama-era procedures for reviewing contractor compensation systems and practices, and replaced it with a new...more

McNees Wallace & Nurick LLC

Compensation: Is it Becoming Employers’ Greatest Vulnerability?

A few weeks ago, a jury in New Jersey federal court found that Lockheed Martin discriminated against a former employee. The employee claimed that Lockheed violated federal and state laws by discriminating against him on the...more

Proskauer - Government Contractor Compliance...

OFCCP Sues Google, Seeking Pay Data

On January 4, 2017, the Office of Federal Contractor Compliance Programs (OFCCP) sued Google, claiming that the tech giant is illegally withholding information about the compensation it provides its employees.  OFCCP seeks...more

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