March 14, 2013

HIGHLIGHTS FROM THE OFCCP PUBLIC BRIEFING

by Keli Wilson, Senior Consultant, DCI Consulting Group

OFCCP officially rescinded the 2006 compensation standards and guidelines and released Directive 307 to replace previous guidance. Directive 307 describes the OFCCP procedures for compliance officers to utilize when reviewing contractor compensation systems and practices during routine compliance evaluations. On March 11, 2013, OFCCP hosted a webinar to discuss the implications of this new directive. Pamela Coukos, senior program advisor, presented this information to the federal contractor community and concluded with a question and answer period.

During the question and answer session, Ms. Coukos stated that OFCCP personnel will be reviewing and updating some of the frequently asked questions (FAQs) to clarify information in the directive. One FAQ response of interest was the following: The ‘snapshot’ date for compensation data submitted in response to OFCCP’s current Scheduling Letter should be the same date used for the organizational profile and workforce analysis provided in the AAP. Currently, federal contractors select the date based on internal resources and other company initiatives such as the merit increase period. Suggesting that the date should be aligned with the organizational profile and workforce analysis provided in the AAP would be a significant adjustment for many federal contractors. As previously mentioned, we are waiting for additional guidance from OFCCP on this FAQ.

Another highlight from the webinar is Ms. Coukos announced that contractors should rely on the verbiage in the scheduling letter where discrepancies between the scheduling letter and directive currently exist. An example of a discrepancy between the two documents is the format in which summary compensation data is being requested at the initial stage of a desk audit. In Directive 307, OFCCP states the following: Summary compensation data submitted in a format other than by AAP job group, or the contractor’s existing pay grade, level or band system, generally is not acceptable for analysis. However, the current scheduling letter requires the contractor to present data in the manner most consistent with the current compensation system (e.g., salary range, rate, grade, level). Again, we expect to receive additional information from OFCCP in an updated release of FAQs.

For those contractors that missed the first session, there will be another webinar available Friday, March 22, 2013 from 11:00 a.m. – 12:30 p.m. (EDT).

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