DCI Consulting Blog

The OFCCP Institute (“The Institute”) recently submitted comments in response to OFCCP’s Proposed Renewal of Information Collection Requirements, published on October 29, 2015, which describes proposed changes to the Scheduling Letter and Itemized...

If the recently passed federal FY2016 budget is any indication, Congress is not pleased with the current direction of OFCCP. The first indication of this displeasure is the actual budget appropriation for OFCCP. OFCCP asked for a $7.2 million...

With OFCCP regularly requesting multiple forms of compensation during compliance audits, we revisit the difference between EEO compliance evaluations of base pay versus other compensation metrics. An individual’s base pay is a function of many...

The OFCCP recently posted two new FAQs confirming that the interpretation, not definition, of “protected veteran” has been broadened to be consistent with the definition used by the Department of Veterans Affairs. As presented in a previous blog,...

In light of some recent buzz centered on OFCCP’s infographic for determining protected veteran status, we wanted to clarify our lastpost and confirm that OFCCP did not change the definition of any veteran categories. As OFCCP and the Solicitor’s...

In the summer of 2014, OFCCP released a Notice of Proposed Rulemaking (NPRM) for collecting compensation data through an Equal Pay Report (EPR) as part of their initiative to combat pay discrimination. The EPR was slated to be final in November of...

The OFCCP Scheduling Letter and Itemized Listing - used to initiate OFCCP supply and service compliance evaluations - is set to expire March 31, 2016. In anticipation of this coming date, OFCCP must obtain approval through Office of Management and...

OFCCP has released a new voluntary poster: Opening Doors of Opportunity for ALL Workers. The poster emphasizes the agency’s goals of diversity and equal opportunity, as well as expectations that federal contractors “must treat workers fairly and...

In another blog, Art Gutman provides an overview of the California Fair Pay Act (CFPA). The CFPA prohibits California employers from paying employees differently due to sex. This is not new, given existing law; however, some of the specifics...

The new California Fair Pay Act (CFPA) is summarized in depth in a previous blog in this series. The CFPA includes strict stipulations for employing “[a] bona fide factor other than sex, such as education, training, or experience” to explain wage...

Prior to the recently enacted California Fair Pay Act (CFPA), federal and state laws and regulations allowed employers to justify sex differences in salaries by using statistical methodologies to control for legitimate pay factors such as education,...

As discussed in this blog series, the California Fair Pay Act (CFPA) was recently signed into law and provides for bona fide factors other than sex to explain wage differentials.  Separate from the final law, it should be noted that a letter from...