After several years of debate and speculation, the OFCCP has finally posted an answer to the question regarding initial compensation analyses in a desk audit. While it may not provide an exact methodology, the answer does provide the basic formula. The details can be found here:
http://www.dol.gov/ofccp/regs/compliance/faqs/emprfaqs.htm
HAS OFCCP DEVELOPED PROCEDURES FOR CONDUCTING A DESK AUDIT OF A CONTRACTOR'S COMPENSATION PRACTICES?
Each of OFCCP's regional offices uses the same basic procedures for conducting a desk audit review of a contractor's compensation practices. Generally speaking, during a desk audit, the agency will examine the following three criteria when evaluating a contractor's compensation practices:
* Whether, for at least one pay division, there is a specified difference in average compensation between the groups being compared and, if so, whether at least one group appears to be adversely affected.
* After combining the pay divisions meeting the above condition, whether the number of employees in the non-favored group is greater than a specified number and represents a specified percentage of the total employees in that group in the overall workforce.
* Whether the overall percentage of the group most adversely affected in the combined pay divisions is larger, by a specified amount, than the overall percentage of the other groups adversely affected.
The specific thresholds used in each of the three criteria above are not static, but rather are subject to change as OFCCP continues to evaluate its targeting methodology.
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