OFCCP’s notice of proposed rulemaking (NPRM) addressing Discrimination on the Basis of Sex is lacking clarity on several points and seems to contradict itself as well. This blog post focuses on the proposed changes to part 60-20.2 General...
Welcome to the DCI Consulting Blog
February 13, 2015
February 10, 2015
As proposed in the Notice of Proposed Rulemaking (NPRM) for the Sex Discrimination Guidelines, sections 60-20.2(b)(7) and 60-20.2(b)(8) of the revised regulations will seem to limit the federal contractor’s ability to recruit and engage potential...
February 06, 2015
Proposed section 60-20.4 “Discriminatory Compensation” in the Notice of Proposed Rulemaking (NPRM) for the Sex Discrimination Guidelines addresses the OFCCP’s enforcement of the prohibition of compensation discrimination as dictated by E.O. 11246....
February 02, 2015
DCI has noted a recent trend among some compliance officers that are alleging that a 1:1 applicant to hire ratio is a “per se” violation of the regulations. If this was true, virtually all contractors would be in violation of the regulations. It is...
January 30, 2015
The EEOC is moving towards the collection of employee compensation data – albeit very quietly. Although no public announcements have been made, the EEOC is conducting a pilot study to investigate issues related to the collection and analysis of this...
January 29, 2015
Last year’s revisions to OFCCP’s scheduling letter included an addition of detailed compensation data (e.g., bonuses, incentive pay, commissions, merit increases, etc.) to be submitted as part of the itemized listing requirements. Predictably, we...
January 21, 2015
DCI predicts that the OFCCP will continue to stay busy in 2015. Here are the top stories and trends we expect to see this year from the agency.
1.) Sex Discrimination Guidelines2.) Construction Regulations3.) Equal Pay Report4.) VETS 42125.) ...
January 21, 2015
On Tuesday, January 20, 2015, the OFCCP released two FAQs clarifying the self-ID requirements under the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA) in light of recent changes to 41 CFR 61-300 (VETS-4212, formerly VETS-100 and...
January 19, 2015
The facts of the case are that Brooke Petkas and a class of female applicants for non-office jobs at Mach Mining sued Mach Mining, arguing that the company had never hired even a single female for non-office jobs. In fact, the company did not even...
January 16, 2015
The term “Ban The Box” refers literally to the “box” on employment application forms that reference criminal background checks. On January 15, 2015 NELP updated from its 2013 report its latest figures on states, counties, and municipalities that...
