OFCCP announced this morning the release of the anticipated final rule implementing Executive Order 13665, commonly referred to as the Pay Transparency Executive Order.  The Rule is expected to be published in the Federal Register on September 11, 2015 and will take effect 120 days from publication –  January 11, 2016. The final rule applies to employers that enter into new, or modify existing, federal contract(s) after January 11, 2016 in excess of $10,000. The final rule amends Section 202 of Executive Order 11246 which already prohibits employment discrimination by federal contractors, and according to OFCCP “helps level the playing field for women and people of color and provides employers access to a diverse pool of qualified talent” by contributing “to building an economy that works for everyone” and helping to “make the contractor workforce more efficient.” Under the final rule employers are required to update their nondiscrimination policies to include a proscribed provision specifically addressing pay transparency.  This language must also be made available to applicants. We are in the process of parsing through the 118 page final rule and will provide additional insights and details soon.

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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.