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A L Y C O N S U L T I N G L L C |
November 29, 2004
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OFCCP Proposes Compensation
Analysis Guidelines
Audit Selection System Update
New Resources for Contractors
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The Office of Federal Contract Compliance Programs (OFCCP) is requesting
comments on proposed guidelines describing how the agency will perform
compensation audits and how contractors can perform a self-evaluation
that assures compliance. The guidelines focus on the use of regression
in analyzing for illegal pay discrimination. Although these are
only proposed guidelines, contractors should take note of the increased
agency focus on more rigorous statistical evaluations during onsite
audits. The guidelines can be found under the Employment Standards
Administration section of the November 16, 2004 Federal Register
(www.access.gpo.gov/su_docs/fedreg/a041116c.html).
Maly
Consulting will be sending comments by the December 16, 2004 submission
deadline and welcome any input from our clients and associates.
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Approximately 1,700 Corporate Scheduling Announcement Letters were
sent to contractors' headquarters earlier this month. These letters
list the establishments that may be audited in the next fiscal year
as determined by the new Federal Contractor Selection System (FCSS).
Note that the announcements were not addressed to a specific recipient
and may include locations audited in the last two years. A sample
of the letter is posted on the OFCCP website at www.dol.gov/esa/ofccp/pdf/FCSS_04.pdf.
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The OFCCP continues to update its website (www.dol.gov/esa/ofccp)
with new resources and information for contractors. This month's
additions include a guide to determining availability, a resource
referral directory, and a general EEO compliance guide for small
businesses.
If you have comments you would like to include in our response to
the OFCCP proposed guidelines or have any questions about any information
presented here, please give us a call or send us an email.
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(415) 454-4921
info@malyconsulting.com |
Edward T. Correro
www.malyconsulting.com |