April 14, 2015 has been identified as National Equal Pay Day – the day which symbolizes how far into the year women must work to earn what men earned in the previous year.
President Obama has made fighting pay discrimination a top priority of his Civil Rights Agenda. He has recently taken several executive actions to further this agenda including:
- Executive Order 13665 – Pay Transparency: Prohibiting discrimination/retaliation against applicants and employees, including employees who discuss pay.
- Equal Pay Report: A report to be filed annually for employers reflecting company-wide compensation. OFCCP is in the process of evaluating the more than 8,000 comments received during the public comment period.
In addition, OFCCP has taken steps to ramp up its enforcement of pay discrimination:
- Directive 307: effective February 2013 and outlines the procedures for reviewing contractor compensation systems and practices during a compliance evaluation
- New Scheduling Letter and Itemized Listing: requires detailed employee-level compensation data to be provided at the outset of every OFCCP compliance review. The data required to be submitted includes:
- Overtime Earned
- Merit Increases
- Incentive Compensation
- Proposed Sex Discrimination Regulations: revises obligations for contractors around pay for women, among other things.
What does all of this mean? The President and OFCCP are serious about addressing pay discrimination and are building programs and processes in furtherance of this goal.
The question is – what are you doing proactively to ensure your company is paying people fairly?
Stay tuned for an upcoming blog post where we will delve into the world of proactive pay analyses and what you can do to gain insight into your compensation systems.