• OFCCP Implements New Investigative Approach Regarding Compensation Discrimination
  • March 11, 2013
  • Law Firm: Alston Bird LLP - Atlanta Office
  • Effective February 28, 2013, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP)—the federal agency responsible for overseeing federal contractors’ compliance with the affirmative action requirements of Executive Order 11246 and several federal statutes—rescinded two Bush-era enforcement documents relating to the agency’s procedures for investigating possible compensation discrimination. The two documents—Interpreting Nondiscrimination Requirements of Executive Order 11246 with Respect to Systemic Compensation Discrimination (the “Compensation Standards”), and Voluntary Guidelines for Self-Evaluation of Compensation Practices for Compliance with Nondiscrimination Requirements of Executive Order 11246 with Respect to Systemic Compensation Discrimination (the “Voluntary Guidelines”)—have now been replaced by newly issued OFCCP Directive 307 (the “Directive”), which replaces all prior OFCCP guidance on compensation investigations and analyses and sets forth the procedures that OFCCP will now use in conducting compliance reviews regarding compensation issues.