March 17, 2015
Location: Virtual Meeting ONLY - GoToMeeting (Please register to obtain login information)
Time: 8:30am - 10:30am
COST: Free to Members and Guests
Speaker: Jim Higgins, Ed.D., Sr. Managing Director of The Higgins Group, LLC Jim Higgins_Bio
The OFCCP is making a clear statement in Item 19 of their revised Scheduling Letter. Contractors will no longer be able to rely on an analysis of a single measure of compensation such as Average Annualized Compensation. Instead, they will be expected to examine compensation from a broader perspective. It is clear from Item 19 that the OFCCP will expect federal contractors to analyze employee pay in terms of Total Compensation. In addition, contractors will be required to submit data for each component that goes into Total Compensation such as Overtime, Bonus/Commission, Stock, etc. This implies that the OFCCP will be analyzing each form of compensation as a kind of Step Analysis of pay--analogous of the way contractors conduct a Step Analysis of the hiring process that leads to the ultimate hire.
Making the process of complying with OFCCP requirements in terms of this more in-depth analysis is the fact that the OFCCP clearly is implying that they will no longer be analyzing pay by comparing Whites vs Minorities. Rather, they are expecting contractors to run their analyses by individual ethnic group and, ultimately, identify statistically significant differences between the “favored” (higher group) and the remaining lesser paid group(s) in each job title or pay analysis group.
These two factors, analyzing multiple measures of employee compensation and comparing the pay on each of these measures across five ethnic groups results in two serious challenges to contractors. First, the methodology required to conduct the analysis has to change from that of the past which relied on independent samples t-tests and multiple regression. Second, the increased complexity of the analysis results in a dramatic increase in the amount of information that needs to be considered by the HR Compliance Analyst in order to identify possible pay discrimination.
Dr. Jim Higgins will break down these issues and provide practical analytical strategies that will help federal contractors navigate these uncharted waters. Further, he will demonstrate how he reports the findings for these complex analyses as one example of how to solve the problems associated with the overwhelming about of information that they can generate. By the conclusion of the presentation, attendees will understand how Item 19, while creating significant challenges, actually holds the promise for making life easier for contractors and provides the opportunity to develop a richer and more complete understanding of how employees are being compensated.
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