Pay Audits, Pay Transparency, and the Public Disclosure of Pay Data
Pay Audits, Pay Transparency, and the Public Disclosure of Pay Data at the 2017 National Conference on Equal Employment Opportunity Law
The pressure has never been higher for employers to conduct pay analyses and publicly declare pay equity—particularly in light of increased attention on the gender pay gap and activist shareholder proposals demanding disclosure of pay data. The OFCCP has enacted new pay transparency regulations applicable to federal contractors, and the EEOC has proposed amending the EEO-1 report to collect aggregated compensation data. States such as California and New York have enhanced their pay transparency rules and anti-retaliation provisions. Additionally, unions use pay equity arguments in bargaining. Some companies like Salesforce have even publicly announced the results of their internal pay audits and the proactive steps they have taken to ensure pay equity. Given this emphasis on pay transparency, disclosure, and reporting, smart employers are analyzing pay to assess risk. Yet determining which employees are “similarly situated” or performing “substantially similar work” for purposes of assessing risk and detecting potential pay discrimination is anything but settled. This program will explore the nuances of conducting pay analyses, as well as discuss the impact of the recent push for pay transparency and public disclosure of pay data.
For more information and to register for this conference, please visit here.
Michael Aamodt, Principal Consultant at DCI Consulting Group, wrote an article featured in SIOP’s TIP publication, January 2017.
DCI has just learned that OFCCP began to send out audit scheduling letters on March 17th. At this time we are not certain how many were sent out, but we do know that 800 CSALs (Corporate Scheduling Announcement Letters) were sent to contractor establishments last month. It is critical that corporate compliance representatives notify individual establishments in their organization to be on the look-out for any official OFCCP correspondence. If you did receive a scheduling notice, please notify DCI immediately so that we can assist you with the audit process.
To read the audit distribution notice, please click here.
By Rosemary Cox, Senior Consultant at DCI Consulting GroupRead More