DCI Consulting Blog

Over the past six months, DCI has continued to monitor OFCCP enforcement trends and priorities regarding compliance evaluations in FY 2016. In our 2015 blog we noted a reduction in the number of new audit scheduling letters received throughout 2015,...

In response to the call for public comments, The Institute for Workplace Equality submitted comments regarding the EEOC’s proposed update to the EEO-1 annual report. The OFCCP Institute’s feedback addresses concerns about the burden estimate and pay...

The original guidance on Title VII & LGBT discrimination was published in December 2012.  The update, which includes recent cases, settlement, amicus briefs was published on 3/1/16 and may be viewed here. The original goals, as stated in the update,...

Today marks Equal Pay Day, which symbolizes the extra days of the year, on average, women must work to earn what men earned in the previous year. Pay equity is attracting a lot of attention in the news, in particular with the tech industry. Facebook...

On March 15, 2016, The Wall Street Journal released an article focusing on the results of pay discrimination investigations carried out by the Office of Federal Contracts Compliance Programs (OFCCP) through their standard compliance review process....

Recently DCI has noted a new trend in OFCCP enforcement of alleged base pay discrimination. Specifically, upon identifying statistical disparities in base pay, OFCCP has proceeded to enforcement under a theory of disparate impact rather than the...

On March 16, 2016, the EEOC held a public hearing on its proposed revisions to the Employee Information Report (EEO-1). The hearing opened with statements from each of the EEOC commissioners. Following the EEOC opening statements, OFCCP Director,...

Federal contractors doing business with the federal government must comply with the regulations enforced by OFCCP and during a compliance evaluation, they must submit all items on the scheduling letter. However, some of the proactive analyses that...

Most scientific studies include people talking about “statistically significant” results that support whatever effect they are examining, typically mentioning p-values less than .05 as sufficient evidence. This is true in adverse impact analyses as...

The application and approval process for entering into a Functional Affirmative Action Program (FAAP) agreement with the OFCCP is outlined in Directive 305 (renumbered to 2013-01), which became effective on December 17, 2012.

The OFCCP is currently...

On February 25, 2016, a Notice of Proposed Rulemaking (NPRM) was published in light of President Obama’s Executive Order 13706. The Executive Order, which was signed on September 7, 2015, requires organizations that enter into covered federal...

In addition to the federal government’s national focus on the gender pay gap, individual states have recently been furthering their own agendas for addressing sex disparities in pay as well. Amendments to fair pay laws in both California and New York