The Office of Federal Contract Compliance Programs (OFCCP) recently issued new investigation standards and procedures as well as a new policy directive for reviewing compensation systems and practices of federal contractors and subcontractors. Directive 307, which will apply to all OFCCP compliance reviews scheduled on or after February 28, 2013, provides for broad investigation of “any observed difference in compensation” and allows OFCCP compliance officers to utilize a wide range of statistical and non-statistical analytical tools in investigating and remedying compensation discrimination.

Directive 307 puts contractors on notice that OFCCP intends to aggressively continue its search for systemic, small group, and/or individual pay discrimination with a broad arsenal of “flexible” and “case-by-case” investigative approaches. For an in-depth analysis of the agency’s new compensation directive, click here to read OFCCP’s New Compensation Directive: The Agency’s Continued Search for Systemic—or Any—Discrimination in Compensation.



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OFCCP Compliance, Government Contracting, and Reporting

The experienced attorneys in our OFCCP Compliance, Government Contracting, and Reporting Practice Group advise and defend federal contractors and subcontractors on jurisdictional, compliance, and enforcement issues relevant to government contracting, including those involving the Office of Federal Contract Compliance Programs (OFCCP).

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