Directive Also Acknowledges That “Occupation Segregation,” Not Pay Discrimination Alone, is a “driver of persistent pay disparities”
Important: This Blog identifies four “Confusions” (and four Resolutions of those Confusions) springing from OFCCP’s new Compensation Directive 2022-01, and also includes one “Happy Observation.”
Confusion #1: OFCCP’s new Directive (DIR) 2022-01 “Subject: Pay Equity Audits” and its accompanying Press Release do not agree on who the audience is. A writer’s first rule is to know the audience to which s/he is writing.
The Press Release says the Directive is written for contractors (which is entirely possible since OFCCP Directives “may provide guidance …to federal contractors”) in these words: OFCCP
“…issued a new directive to promote greater contractor attention (emphases added) concerning the proactive and effective use of pay equity audits to identify barriers to equal pay in their pay-setting and employment practices.”
The Directive, however, is aimed at OFCCP and says:
“PURPOSE: To provide guidance on how OFCCP will evaluate federal contractor’s compliance with pay equity audit obligations and clarify OFCCP’s authority to access and review pay equity audits conducted pursuant to 41 CFR 60-2.17(b)(3).”
The Directive also sets out perfunctory generalized role instructions for various levels of OFCCP employees even while the Directive seems written for the contractor audience....
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