David Cohen, President, DCI Consulting Group, Inc., offers another unique “inside the Beltway” perspective on important OFCCP developments:
National Office to Vet Systemic Compensation Investigations Post Desk Audit
Many DCI clients are wondering what role OFCCP’s national office will play when a field office wants to pursue a systemic compensation investigation against a contractor based on the results of the desk audit. Based on my recent conversations with senior OFCCP officials, all such investigations will be vetted in advance with OFCCP’s national office. This is good news for contractors because it should result in OFCCP applying a uniform approach towards systemic compensation discrimination investigations across regional lines.
OFCCP Developing Internal Policy Manual On Conducting A Compensation Analysis
DCI has also learned that OFCCP is working on an internal policy manual that will outline how the field should conduct a compensation analysis at the desk audit stage. The document, which is now under review by the Solicitor of Labor’s office, will be disseminated to field staff after it has been approved internally.
In the meantime, OFCCP is continuing to roll out training programs to its field staff on conducting a compensation analysis. Not surprisingly, the district and regional offices are still going through a sharp learning curve on the new Compensation Standards and Voluntary Guidelines. For example, DCI has heard that some field offices are under the mistaken impression they can only analyze compensation at the desk audit stage by job or grade. In other words, if a contractor wants to hand over their SSEGs for analysis at the desk audit stage, some offices will not take them. We hope OFCCP’s new training programs along with their new internal compensation analysis manual will be useful tools to make desk audit compensation protocols consistent throughout the regions.
