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Playing Favorites? or Enforcing Systemic Equal Pay?

May 21, 2013

When examining pay equity issues, the OFCCP and federal contractors historically took the approach of comparing Whites to an aggregate of all protected groups (total minorities). In the past few years, OFCCP has moved away from a White-Minority...

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Compliance Assistance: Have No Fear

May 21, 2013

OFCCP recently reiterated that Federal contractors or subcontractors seeking compliance assistance from the OFCCP can do so without fear of retaliation, in the form of a compliance evaluation, as expressed in the OFCCP’s Non-Retaliation Policy for...

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OFCCP Announces Date for Required Use of 2006-2010 Census Data

May 16, 2013

OFCCP announced May 15, 2013 that federal contractors will be required to use data from the 2006-2010 special EEO file starting January 1, 2014. Meaning, federal contractors with an affirmative action plan date of January 1, 2014 or later will need...

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WHAT IS THE STATUS OF PROPOSED VETERAN (4212) AND DISABILITY (503) REGULATIONS?

May 07, 2013

Based upon the FY 2013 Budget Request to Congress, OFCCP planned to release in final form the Veterans and Disabilities regulations sometime in April of 2013. However, those regulations are still at OFCCP going through “revisions” and have not been...

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Bertucci Contracting Settles Race Discrimination Case with OFCCP

May 07, 2013

Bertucci provides flood control and restoration services and has received more than 80 million in federal contracts related disaster recovery efforts, most notably, in the wake of Hurricane Katrina in 2005 and the British Petroleum oil spill in...

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DISTRICT COURT AFFIRMS UPMC HOSPITALS ARE FEDERAL SUBCONTRACTORS

April 23, 2013

Three hospitals affiliated with the University of Pittsburgh Medical Center (UPMC) were considered subcontractors by District Court Judge Friedman on March 30, 2013. The case is UPMC Braddock v. Harris and includes UPMC Braddock, UPMC McKeesport and...

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Compliance Evaluations: From Courtesy Letter to Scheduling Letter

April 23, 2013

Given the recent wave of OFCCP courtesy letters sent to federal contractors this month, we thought a short review of the process in moving from courtesy letter to scheduling letter would be of interest to readers of this blog. The OFCCP utilizes the...

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OFCCP Audit Punch List

April 23, 2013

Given the recent wave of OFCCP courtesy and scheduling letters, we thought that a blog on early preparations in the OFCCP audit process would be of interest. Recall that all federal contractors and subcontractors in receipt of a supply and service...

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Outreach to Veterans: Are You Meeting Your Obligations?

April 09, 2013

Federal contractors and subcontractors that are covered under the Vietnam Era Veteran’s Readjustment Act of 1974 (VEVRAA) are required to take affirmative action in employing and advancing covered veterans. In practice, this means that contractors...

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RACE/ETHNICITY SUBGROUP ANALYSIS IN COMPENSATION ANALYSES: A CHANGE IN OFCCP PROTOCOL

April 09, 2013

OFCCP’s recent webinars on Directive 307 stated that compensation investigations will focus on individual race/ethnicity differences. If that is the case, a number of analytic questions require clarification.

  • Is the comparator group “White” or is...
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Issued Courtesy Letters Take Place of CSAL

April 09, 2013

OFCCP recently issued a large wave of announcement letters, as noted in the blog last week. These letters are in the form of the same “courtesy” letters that were sent at the end of 2012, rather than the traditional Corporate Scheduling Announcement...

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What Changed With Directive 307?

April 09, 2013

OFCCP’s Directive 307 outlines policies for evaluating compensation data that depart in three primary ways from guidance presented in the rescinded Compensation Standards:

  • No requirement to construct and analyze compensation data by Similarly...
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