The National Industry Liaison Group (NILG) and OFCCP held a Compensation Roundtable on February 18, 2020.  The roundtable included representatives from the OFCCP, Women’s Bureau, and the private sector.  Much of the roundtable consisted of the OFCCP listening to concerns and recommendations of lawyers/federal contractors about compensation analysis and enforcement during audits. 

Below are some following topics discussed:

  • The OFCCP’s approach to compensation reviews using the current compensation directive (Directive 2018-05).
  • Experts’ recommendations for improving the Directive and its application.
  • How best to identify pay disparities.

Below are some key conclusions:

  • Each company’s pay systems and data are complex and unique and the OFCCP should look at the company’s unique pay structure and what are the drivers of pay at that specific company.
  • Compensation analysis during an audit can become difficult because there are many underlying factors of pay and unique circumstances which cannot always be assigned a numeric value. 
  • The challenge for the OFCCP is to write an updated directive that will be relevant for all federal contractors.