Compensation Urban Legends
Since rescinding the Standards and Guidelines and issuing Directive 307, OFCCP has been exploring novel theories of discrimination and applying unusual analytic strategies in its investigations. The past two years of OFCCP audits, in particular, to which DCI has been exposed have illuminated the agency’s perspective on what types of data aggregation and analytic strategies are consistent with Title VII of the Civil Rights Act of 1964. Respectfully, DCI strongly disagrees with OFCCP’s apparent approach to investigating potential compensation discrimination in such matters. In this webinar, we highlight some of the most problematic ‘myths’ of compensation analyses to which we have seen OFCCP subscribe.
- All forms of compensation (base pay, bonuses, overtime, etc.) can be combined into ‘total compensation’ and effectively analyzed using a single pay model.
- Different groups of similarly situated employees can be grouped together (i.e., aggregated) and effectively analyzed.
- A pay factor that correlates with protected group status is ‘tainted.’
- A statistical disparity in an aggregation of similarly situated employee groups (SSEGs) forming a pay analysis group (PAG) indicates that there are unexplained differences between protected classes in each SSEG forming the PAG.
Please note: this complimentary webinar is reserved for DCI clients, federal contractors and law firms.
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DCI Consulting is a risk management human resources consulting firm strategically located in Washington, D.C.