VIA: https://www.regulations.gov/ &
U.S. Mail, First Class
Ms. Debra A. Carr
Director
Division of Policy, Planning, and Program Development
Office of Federal Contract Compliance Programs
U.S. Department of Labor
Room N3422
200 Constitution Ave., NW
Washington, D.C.20210
RE: Interpretive Standards for Systemic Compensation Discrimination
and Voluntary Guidelines for Self-Evaluation of Compensation
Practices Under Executive Order 11246; Notice of Rescission
Reference: 1250-ZNE
Dear Ms. Carr:
This letter is submitted in response to the Notice of Proposed Rescission with respect to the Interpretive Standards for Systemic Compensation Discrimination (“Standards”) and Voluntary Guidelines for Self-Evaluation of Compensation Practices (“Guidelines”) Under Executive Order 11246 (“Executive Order”) by the U.S. Department of Labor (the “Department” or the “DOL”) published January 3, 2011 with respect to 41 CFR Parts 60-1 and 60-2. The underlying Standards and Guidelines relate to certain nondiscrimination requirements of the Executive Order, those designed to ensure that federal contractors do not discriminate in compensation against employees on the basis of race, color, national origin, religion, and sex. More broadly, the Executive Order also provides that federal contractors shall take affirmative action to ensure that vestiges of discrimination are removed from their employment practices. To achieve the affirmative action objective, contractors must engage in an effort to affirmatively recruit minority and female candidates and develop affirmative action plans (“AAPs”) that analyze the composition of the workforce and prescribed human resource activities that occur during a one-year period.
These comments are submitted on behalf the (1) Center for Corporate Equality (“CCE”); (2) College and University Professional Association for Human Resources(“CUPA-HR”); (3) Fortney & Scott, LLC; (4) Mercer ORC Networks (“ORC”); and (5) Society for Human Resource Management (“SHRM”).