A Closer Look At OFCCP's New Compensation Directive
Law360 (October 1, 2018, 1:32 PM EDT) -- On Aug. 24, 2018, the U.S. Department of Labor's Office of Federal Contract Compliance Programs released Directive 2018-05, "Analysis of Contractor Compensation Practices During a Compliance Evaluation." Although this directive appears to be more transparent than the agency's 2013 Directive 307, there are components outlined in the directive that do not align with some basic pay equity analytical principles. Below is a summary of the aspects of the directive that are helpful, or "good," to the federal contractor community and pay equity enforcement; the worrisome, or "bad," aspects for federal contractors; and other "ugly" questions in the aftermath of a new...
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