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Expert Analysis

A Closer Look At OFCCP's New Compensation Directive

By Joanna Colosimo and David Cohen (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."[1] Although this directive appears to be more transparent than the agency's 2013 Directive 307,[2] 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 compensation-focused directive....

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