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OFCCP Financial Settlements: FY2013 Trends

October 29, 2013

The US Department of Labor makes enforcement data collected by the OFCCP searchable to the public. Although the recent government shutdown has prevented the agency from updating the database to include settlements through the end of the federal...

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Medtronic Settles With OFCCP On Wage Discrimination Charges

October 08, 2013

In a news release dated 9/23/13, the OFCCP announced a $290,000 settlement with Medtronic Interventional Vascular Inc., a wholly owned subsidiary of Medtronic (see https://www.dol.gov/newsroom/releases/ofccp/ofccp20131811). The OFCCP alleged that 78...

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Choose Your Own Comparator: The Importance of Race Coding Strategy in Compensation Equity Analyses

October 01, 2013

In a prior blog post, we indicated that OFCCP has taken a position that the specific strategy for dummy coding races in a regression analysis does not matter. Specifically, they have argued that the group that one chooses as the referent group is...

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DCI Staff Attend 31st ILG Annual Conference Held in Indianapolis

August 14, 2013

The 31st Annual National Conference for the Industry Liaison Group (ILG) was held July 30 – August 2, 2013 in Indianapolis, IN. This annual conference brings together members of the federal contracting community to discuss affirmative action and...

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OFCCP RELEASES DIRECTIVE 310 PROVIDING GUIDANCE ON BACK PAY CALCULATIONS

July 25, 2013
OFCCP has released Directive 310 to provide guidance on calculating back pay as a part of make whole relief for victims of employment discrimination when using formula or individual relief. DCI is currently reviewing this new directive and will...
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INITIAL EFFECTS OF DIRECTIVE 307 DURING OFCCP AUDITS

July 23, 2013

In light of the recent OFCCP Directive 307, DCI has noted trends during audit situations related to how OFCCP staff are interpreting and enforcing the directive.

In some Regional and District Offices, there are circumstances where compliance...

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Subgroup Analyses Under Directive 307: Awaiting an Update From OFCCP

July 23, 2013

Since its release in February 2013, Directive 307 has certainly been on the mind of federal contractors. This blog has covered a number of issues related to Directive 307 that may make proactive analyses of pay equity complicated. One such issue...

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Equal Pay Enforcement: What Do The Laws Say?

June 18, 2013

Art  recently described a pay equity ruling that was declined for review by the Supreme Court. At the heart of the ruling was the difference between pay equity under Title VII versus the Equal Pay Act. We thought a follow up blog on the matter would...

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Directive 307: More Thoughts on Proactive Analyses

June 04, 2013

This blog continues the ongoing discussion of the implications of Directive 307 on proactive pay equity analyses. As discussed in an earlier blog, deciding which racial/ethnic subgroups to compare in a pay equity analysis and at which unit of...

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More Musings on Directive 307

June 03, 2013

Over the last few weeks, DCI staff members have written a number of blogs related to OFCCP’s pay equity directive. These blogs have focused on some of the challenges federal contractors will likely face when conducting proactive pay equity research...

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THE INCREASED LIKELIHOOD OF FALSE POSITIVES UNDER DIRECTIVE 307

May 21, 2013

In an ongoing series of blog posts, we will be dissecting portions of Directive 307 to highlight the potential pitfalls with the Directive’s prescriptions for conducting pay equity analyses. At issue this week is OFCCP’s oversight regarding the...

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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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