Subgroup Analyses Under Directive 307: Awaiting an Update From OFCCP

Since its release in February 2013, Directive 307 has certainly been on the mind of federal contractors. This blog has covered a number of issues related to Directive 307 that may make proactive analyses of pay equity complicated. One such issue raised in a previous blog concerns who the referent group should be when conducting these analyses. Traditionally the referent group was whites or males. However, under Directive 307 it is unclear who the referent group should be. If consistency with the Uniform Guidelines on Employee Selection Procedures (UGESP) policy on adverse impact analyses is desired, then the highest-selected (i.e., paid) group would be the referent group.

The Center for Corporate Equality (CCE) previously submitted specific questions to OFCCP on this issue immediately following a Directive 307 webinar hosted by the agency in March 2013. CCE has followed up on this issue and although no new guidance has been received, the latest correspondence with OFCCP suggests that this issue, among others raised during and post-webinar, will be addressed at the National ILG conference later this month. Stayed tuned for updates.

by Amanda Shapiro, M.S., Consultant, and David Cohen, M.S., President, DCI Consulting Group

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