Unpacking OFCCP’s Pay Equity Audits Directive: Considerations in Preparing Non-Privileged Pay Analyses

On March 15, 2022, the Office of Federal Contract Compliance Programs (OFCCP) announced that covered federal contractors must perform annual pay equity audits to comply with affirmative action program (AAP) regulatory requirements. The agency has stated that contractors must provide these pay equity audits to OFCCP upon request and that such audits are not protected from disclosure under the attorney-client privilege or work product doctrine. In this webinar, the speakers will share their insights on OFCCP’s directive as well as provide strategies to consider when preparing voluntary pay equity analyses.