Tag Archives: OFCCP

Employers Must Use Caution When Basing Pay Decisions On Prior Salary History

Employer
Imagine a scenario where an employer hires two individuals – a male and female – to fill two identical jobs (i.e., same job qualifications and same job duties). Both individuals satisfy the educational, skill, and other technical requirements for the job and they have similar employment histories.  However, at their prior places of employment, one … Continue reading this entry

Uncle Sam Wants You! (to Provide Employee Compensation Data)

harassment
A new lawsuit filed by the U.S. Department of Labor (DOL) demonstrates how dogged the government can be in trying to obtain and review employers’ compensation data. The lawsuit, filed against Google with the DOL’s Office of Administrative Law Judges, alleges that Google failed to comply with its obligations to provide compensation data to the … Continue reading this entry

What Will Happen When the Smoke Clears? Post-Election HR Strategies for 2017 and Beyond

Trade Secrets
The long and contentious presidential campaign is over.  So, now what?  What does President-elect Trump’s victory mean for employers? To explore this question, Foley and Lardner LLP’s Labor & Employment Practice group hosted a webinar titled “What Will Happen When the Smoke Clears? HR Strategies for 2017 and Beyond” on November 10, 2016.  The team … Continue reading this entry

EEOC’s Revised Proposal to Collect Pay Data Keeps Focus on Pay Discrimination Agenda

li_eeoc
As we reported previously, enforcement of equal pay laws and remedying of pay disparities continue to be top priorities for the U.S.Equal Employment Opportunity Commission (EEOC) and U.S. Office of Federal Contract Compliance Programs (OFCCP). The EEOC again highlighted this ongoing focus this past week when it announced revisions to its February 2016 proposal to … Continue reading this entry

Moving Away From The “Mad Men” Era: The OFCCP Updates Its Sex Discrimination Guidelines

discrimination
For the first time since 1970, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) is updating its sex discrimination guidelines for federal contractors. These updates, announced last week, will become effective on August 15, 2016. Most companies subject to the OFFCP’s oversight – including businesses that perform work for the federal government … Continue reading this entry

Tell Me How Much My Coworkers Make… Or I’ll Sue You

Employer
The Office of Federal Contract Compliance Programs (OFCCP) – an agency of the Department of Labor – has enacted a rule requiring federal contractors and subcontractors to disclose information regarding pay practices and compensation to any inquiring employee or applicant. The rule does not require employers to directly inform individuals about pay practices or data, … Continue reading this entry

Responding to a Scheduling Letter From the OFCCP: The Little Things Matter

la_affirmative
It is the Tuesday after a long holiday weekend, and you are faithfully going through the pile of mail on your desk when you spy an envelope from the United States Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP). You open the envelope and, sure enough, your facility has been selected for a … Continue reading this entry

Another Day, Another Rule for Federal Contractors

Discrimination
As we previously noted, federal contractors have been besieged in recent months with regulatory changes and enforcement initiatives advanced by the Office of Federal Contract Compliance Programs (“OFCCP”) and various divisions within the Department of Labor (“DOL”). The holiday season has not offered any relief, as the DOL recently announced its final rule implementing Executive Order … Continue reading this entry

The "Equal Pay Report" - Yet Another New Regulation Requiring Compliance by Federal Contractors

Wage and Hour
The Equal Pay Report – yet another obligation being imposed on federal contractors is coming to you soon. The Office of Federal Contract Compliance Programs (“OFCCP”) released information on another new rule that will require all federal contractors and subcontractors to prepare and file a summary compensation report on an annual basis. The Proposed Rule was … Continue reading this entry

Staying on Top of Federal Contractor Regulations

di_affirmative
Earlier this year, the OFCCP began enforcement of extensive amended regulations on Affirmative Action Plans (AAP) and recordkeeping requirements for both protected veterans (VEVRRA) and persons with disabilities (Section 503). These regulations require significant modification to existing AAP, including new requirements for data collection, outreach, and training, “benchmarks” and goals. Companies and entities dealing with … Continue reading this entry

OFCCP to Put Contractors' Compensation Systems Under a New Microscope

In recent months, various agencies tasked with enforcing federal labor and employment laws have been a hotbed of activity — publishing guidance memoranda, enforcement directives, and the like. The Office of Federal Contract Compliance Programs (OFCCP) is no exception.… Continue reading this entry

The OFCCP Is at It Again — Revision to Compliance Requirements Is a “Game Changer”

Under the Obama administration, many Department of Labor agencies have stepped up their non-discrimination enforcement activities. The Office of Federal Contract Compliance Programs (OFCCP) has stepped up enforcement even more than most. The latest OFCCP effort is a revision to the regulations on affirmative action for employers as it relates to persons with disabilities. On … Continue reading this entry

The Expanding Reach of the OFCCP -- Are You a Government Contractor?

We’re not a government contractor?! Or so you thought. Many employers are, in fact, government contractors because they have a federal contract or subcontract with the federal government, or participate in federally assisted construction projects (i.e., DOT funds given to states and then states issuing contracts to contractors). Being a government contractor requires compliance with … Continue reading this entry