Tag Archives: Directive 307

BREAKING NEWS: OFCCP Issues New Compensation Directive and Other Directives

It’s here!  OFCCP has finally issued its long-awaited, much-anticipated, new compensation directive.  The Directive explicitly replaces the controversial Directive 307 and sets out the Agency’s current approach, and commitment to transparency, with respect to pay equity analyses. Directive 2018-05: Analysis of Contractor Compensation Practices During a Compliance Evaluation outlines “standard procedures for reviewing contractor compensation practices during a … Continue Reading

OFCCP Working on Contractor Certification Program

Following the tone of the preceding days, the 2018 ILG National Conference closed Friday morning with a friendly conversation between Acting Director Craig Leen and NILG Chair Paul McGovern.  The two discussed several of the themes and OFCCP initiatives addressed during the conference: Transparency, certainty and the Rule of Law The Agency’s audit scheduling process Directive 307 and pay … Continue Reading

OFCCP Releases “Town Hall Action Plan” to Address Contractor Concerns

In the words of OFCCP, the contractors spoke and OFCCP listened.  OFCCP is also listening to the Government Accountability Office and its detailed review of the Agency. In response to the GAO’s Strengthening Oversight Could Improve Federal Contract Nondiscrimination Compliance report and on the heels of OFCCP’s Compliance Assistance Town Halls, the Agency has developed a … Continue Reading

Breaking News: OFCCP Could Be Close To Rescinding Current Compensation Directive

Bloomberg Law is reporting OFCCP may soon rescind the controversial Directive 307, which has been in place since early 2013, and sets out the Agency’s current methodology for analyzing pay.  In its place, Bloomberg reports OFCCP will direct compliance officers to review compensation based on pay groupings established by the contractor.  If the directive is rescinded and … Continue Reading

Final Revised Overtime Rule Released by Department of Labor

The U.S Department of Labor’s Wage and Hour Division has finalized its much anticipated revisions to the rules governing overtime compensation. The revisions, in part, increase the income level of those who are exempt from overtime pay to $47,476, almost doubling the prior threshold, allowing a greater number of employees to qualify for overtime pay. According … Continue Reading

The New Tool in OFCCP’s Compensation Enforcement Toolbox: Compensation Manager Interviews

Compensation – it’s on everyone’s mind and it’s what everyone was talking about at the 33rd Annual ILG National Conference in New York City.  Conference attendees, government officials and practitioners alike were all talking about pay and the tools available to employers and agencies to identify and investigate compensation issues. Our Jackson Lewis colleague Scott M. Pechaitis has put together his thoughts … Continue Reading

National Equal Pay Day

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 … Continue Reading

There’s Still Time to Comment on OFCCP’s Proposed Sex Discrimination Rules

OFCCP published its long-awaited Sex Discrimination Rules amidst a lot of other activity vying for our attention.  Maybe you’ve not had the chance to review them (yet). But you’ve still got time.  The public comment period is open until Tuesday March 31, 2015 – let your voice be heard. Comments can be filed via fax or … Continue Reading

SWARM Conference Ends on a High Note: OFCCP Shares its View on Pay Investigations

On the last morning of the 2014 SWARM Regional Conference, attendees were treated to a special session with OFCCP officials and practitioners discussing OFCCP’s approach to pay enforcement.  On the panel from OFCCP were SWARM Regional Director Melissa Speer and Deputy Director of Operations, Marika Litras who graciously and skillfully filled in for an ill … Continue Reading

Join Jackson Lewis Attorneys for The OFCCP Institute’s Annual Summit in DC – May 20th-22nd

Its about one month since OFCCP’s new rules covering Veterans and Individuals with Disabilities became effective and the agency is starting to vigorously enforce the new rules.  Combined that with OFCCP’s increasingly aggressive enforcement of Directive 307 – which sets forth the agency’s new approach to investigating employers’ compensation systems for systemic discrimination – and … Continue Reading

The OFCCP Institute Fall 2013 Conferences in Houston, Washington, DC and Los Angeles – Mickey Silberman to be Featured Presenter

In just the past few months, OFCCP published Directive 307 – radically changing the way the Agency conducts pay investigations – issued the revised Federal Contractor Compliance Manual (FCCM), and announced the new Veterans and Disability regulations.  All told, more than 1,000 pages of new/revised/updated rules, regulations and enforcement methods.  Let’s give OFCCP points for … Continue Reading

Breaking News: OFCCP Sends Out Large Wave of Advance Notice Letters Notifying Employers of Compliance Audits

On March 27, 2013 OFCCP sent out a wave advance notice letters –referred to as CSAL’s – to employers across the country.  In November, 2012, OFCCP emailed more 1,750 CSALs.  We have learned the number of CSAL’s mailed last week exceeds the last round of notifications sent in November.  As result, employers can expect a … Continue Reading

OFCCP Offers Insights Into Agency’s New Compensation Directive

In a public webinar held earlier this week, OFCCP provided listeners with information and insights into the Agency’s recent rescission of the 2006 Compensation Standards and the implementation of Directive 307. As OFCCP’s Notice of Rescission made clear, the Agency felt constrained by the 2006 Standards and the new “case-by-case” approach to pay investigations will … Continue Reading

UPDATE: Additional Insights into OFCCP’s Rescission of Compensation Standards

As an update to our breaking news post yesterday, we have published additional, initial, thoughts on OFCCP’s rescission of its Compensation Standards and the impact of the Agency’s new pay investigation procedures. See the following article on the Jackson Lewis website:  OFCCP Rescinds Compensation Standards and Will Develop New ‘Case-by-Case’ Investigative Approach. We continue to digest … Continue Reading