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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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Goodwill Industries Settles Sex Discrimination Case Against Males with OFCCP for $130,000

May 21, 2013

The settlement was reported on the OFCCP website on April 25, 2013. According to the release, the hiring process favored women for entry-level attendants because of the perception that women are better than men at customer service. This settlement...

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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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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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HIGHLIGHTS FROM THE OFCCP PUBLIC BRIEFING

March 14, 2013

by Keli Wilson, Senior Consultant, DCI Consulting Group OFCCP officially rescinded the 2006 compensation standards and guidelines and released Directive 307 to replace previous guidance. Directive 307 describes the OFCCP procedures for compliance...

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