OFCCP Publishes Final Standards for Analysis of Systemic Compensation Discrimination
It may seem like a long time ago, but we made a posting back in November, 2004, regarding OFCCP’s proposed standards for analysis of Systemic Compensation Discrimination.
As of June 16, 2006, OFCCP has posted its final standards for analysis of systemic compensation discrimination.
These final standards follow a detailed discussion of the comments received by OFCCP regarding the proposed standards.
Although I have not had the time to do a thorough review of the final standards, it is noteworthy that OFCCP maintains that:
In determining whether a violation has occurred, OFCCP will also consider whether there is anecdotal evidence of compensation discrimination, in addition to statistically significant compensation disparities. Except in unusual cases, OFCCP will not issue an NOV [Notice of Violaton] alleging systemic compensation discrimination without providing anecdotal evidence to support the statistical analysis….
For further information on OFCCP’s final standards, see:
- News release: “OFCCP Issues First Compensation Discrimination Standards, Publishes New Guidelines for Compensation Self-Analysis.”
- Federal Register Notice:
“Office of Federal Contract Compliance Programs; Interpreting Nondiscrimination Requirements of Executive Order 11246 With Respect to Systemic Compensation Discrimination.”
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