Earlier this month, President Obama proclaimed April 8, 2014 to be National Equal Pay Day – the day that indicates how far into 2014 a woman must work in order to earn the same amount that men did in 2013. On the heels of that proclamation, President Obama issued a presidential memorandum directing the Department of Labor ("DOL") to propose rules that will require federal contractors and subcontractors to submit summary read more

When thinking about the new developments in the OFCCP's jurisdictional dispute with TRICARE network providers, the old adage about March weather came to mind. (The crazy spring weather we are experiencing probably also had something to do with prompting the analogy). In case you are not familiar with this ongoing saga, let me provide some read more

Before we can expect individuals with a disability to openly communicate, through the self-identification process, their disability and possibility a need for an accommodation, we must show them that the information will not be viewed or used in a negative way. In order to do this, we must take a multi-prong approach of education and communication, both externally and internally, within the organization. read more

On page 48 of the July 2013 Federal Contract Compliance Manual (FCCM) the OFCCP describes its methodology for calculating the impact ratio and how the compliance officers (CO) are supposed to use the results of the impact ratio analyses:

Although related, a CO must not confuse adverse IRAs with the read more

In hiring, termination and promotion cases, the analysis examines each step of the decision making process to determine who should have been equally likely to be selected for the particular employment event. For example, in hiring at each stage you look at who remained eligible to progress to the next stage. Ultimately, the investigation should arrive at the final stage where selection rates of the remaining eligible individuals (the refined read more

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