New Tool in OFCCP’s Compensation Enforcement Toolbox: Compensation Manager Interviews

As the Obama Administration continues to make headlines promoting “equal pay,” the directive from the White House to EEOC and OFCCP is, “we know pay discrimination exists – go find it.” OFCCP, which historically has not brought back a lot of compensation discrimination findings and settlements, has sharpened the tools in its compensation investigation toolbox, including the following:

  •  Rescission of Longstanding Compensation Standards and Voluntary Guidelines

  • Directive 307

  • Strategic Additions to Headcount

  • Updated Audit Letter/Itemized Listing

  • Presidential Executive Orders re: Pay

Over the last two years, OFCCP has systematically overhauled its approach to investigating pay discrimination. And now, the Agency has developed yet another investigatory tool – compensation manager interviews.

National Law Review