Since the National ILG conference in August of 2010 where the OFCCP declared that the old Trigger tests were not being used anymore, the Federal contractor community has been asking what OFCCP is using to determine if a contractor has a potential compensation issue that should be investigated. On March 16th, speakers at the Northern California and Southern California Industry Liaison Group meetings let it be known that the OFCCP does in fact have a Trigger test in effect.
The OFCCP takes the summary compensation data provided in the Desk Audit Letter under Item #11 and regardless of how the data is submitted (i.e. job group, job title, etc.) the OFCCP will flag either a 2% OR $2,000 difference in pay.
The expectation being that if any result is flagged as the OFCCP's Directive requires the compliance officer to request employee level data for the entire workforce. The OFCCP would then conduct further analysis of the data.
In the meantime, the EEO industry awaits word on the anticipated revision to the OFCCP compensation guidelines in addition to the results of the recent request for comment on the tool that OFCCP will use to collect compensation data in the future.
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"The OFCCP takes the summary compensation data provided in the Desk Audit Letter under Item #11 and regardless of how the data is submitted (i.e. job group, job title, etc.) the OFCCP will flag either a 2% OR $2,000 difference in pay.The expectation being that if any result is flagged as the OFCCP's Directive requires the compliance officer to request employee level data for the entire workforce. The OFCCP would then conduct further analysis of the data."
This is a very interesting post. Thank you for sharing!
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