M A L Y   C O N S U L T I N G   L L C
November 29, 2004
Compliance Alert

OFCCP Proposes Compensation Guidelines

Contents
   OFCCP Proposes Compensation Analysis Guidelines
   Audit Selection System Update
   New Resources for Contractors

OFCCP Proposes Compensation Analysis Guidelines  top ^
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.

Audit Selection System Update  top ^
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.

New Resources for Contractors  top ^
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.

(415) 454-4921
info@malyconsulting.com
Edward T. Correro
www.malyconsulting.com
990 A Street, Suite 402 • San Rafael, CA 94901 • (415)454-4921 • Fax (415)454-4914
© Copyright 2004,  M A L Y   C O N S U L T I N G   L L C