Update: OFCCP and Compensation Discrimination: Changes in the Air

I just located the documents referred to in this posting, including the document for determining whether pay discrimination exists, and a document covering a self-examination of one’s pay system.

This memo from Ogletree & Deakins indicates that the OFCCP will be proposing two documents pertaining to analyzing pay discrimination. The first, and to me the more interesting, concerns how pay is analyzed for possible discrimination. In particular, the proposed new standards officially reject

the DuBray method, and instead offer a different approach, heavily emphasizing multiple regression analysis.

The other proposal offers much greater reliance on a self-audit.

Both proposals should be published shortly and the public may make comments for about one month.

Read more details here.

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