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Compensation Analysis for OFCCP Compliance
Situation:
A
division of a major manufacturer was preparing for a compliance
review of their Affirmative Action Plan by the Office of Federal
Contract Compliance Programs (OFCCP). The company requested an
independent third party to conduct an analysis of its compensation
practices in preparation for the compliance review
Process
D.G. McDermott Associates conducted a
compensation analysis in the same manner that the OFCCP performs
its reviews. The analysis covered a business unit with approximately
9,000 employees to determine the factors which influence pay.
Solution
Based on its analysis, D.G. McDermott
Associates recommended the following:
-
A
review of the Affirmative Action Plan to ensure that the correct
parameters were covered for purposes of consistency with its
analysis
-
Modifications
to its pay programs to minimize inadvertent prima facie discrimination
issue
-
So
as not to limit the review to current compensation rates,
an examination of the following areas was required: starting
salaries, promotion practices, tenure in the company and
the job, etc., as factors which may influence pay
Outcome
The
company adopted D.G. McDermott
Associates' recommendations
and successfully completed the compliance review.
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