The Office of Federal Contract Compliance Programs has issued Directive 2022-01, Pay Equity Audits. It makes clear that pay equity is at the forefront of the OFCCP’s enforcement agenda, and issues a shot across the bow in the Agency’s longstanding battle with contractors regarding whether internal pay equity analyses must be produced to the Agency during an audit. In light of this Directive, contractors should expect that OFCCP will aggressively and expansively examine not only employee compensation, but also assignment and promotion practices as elements of compensation systems, and will demand the production of any company pay equity analyses should the Agency’s initial assessment of compensation data indicate any disparities.
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