Developments in Compensation Webinar

ERA will conduct a webinar on recent compensation developments on September 10, 2015 from 1:00 to 2:00 EST. The complimentary hour long webinar will cover the new compensation reporting requirements and also how the OFCCP is using the new data and focusing on equal pay in audits.


The Office of Federal Contract Compliance Programs (OFCCP) has made compensation and pay equity a focus in compliance reviews. The OFCCP audit letter, which was revised in October, 2014, has an expanded compensation data request including specific accounting for bonuses, commissions, overtime and other pay. The OFCCP is also requesting interviews with the employee or employees who manage compensation.

Under the Code of Federal Regulations, federal contractors are required to undertake a self-analysis of compensation and ensure that employees are being paid fairly without regard to protected status. However, a simple analysis by base pay may fall short. The OFCCP is examining compensation information using much more sophisticated methods including regression analysis which allows multiple pay factors to be compared. The OFCCP is also attempting to group jobs in Pay Analysis Groups (PAG's) rather than job titles. The concern is that the OFCCP may be grouping employees together into PAG's who should not be compared for pay purposes.

ERA offers compensation analysis and we are expanding our offerings to include these new areas of analyses-- bonuses, commissions, overtime and gross wages. Contractors should be aware that the OFCCP may request the self-analysis prepared and contractors must submit it unless protected by attorney-client privilege. Attorney-client privilege can be established where an attorney, on behalf of the contractor, requests the compensation analysis and strict controls are placed on the release of the analysis by the attorney to the contractor (whether external or internal counsel).


Webinar Free to Members