Client Alert
Affirmative Action Compliance in 2005: OFCCP Issues Proposed Standards Governing Compensation Discrimination Analyses
December 06, 2004
Nancy L. Abell and Jon A. Geier
As the Bush Administration prepares for its second term, the United States Department of Labor, Office of Federal Contract Compliance Programs, pursues a vigorous enforcement agenda that is reshaped by several developments governing federal government contractors and subcontractors. The most significant is the OFCCP’s proposed guidelines for systemic compensation discrimination published on November 16, 2004. Selection of contractors for compliance evaluations will be governed by the new Federal Contractor Selection System, pursuant to which the OFCCP will give advance notice of valuations and limit the number of evaluations of any contractor in a year to 25. The content of 2005 have been added in recent years and the contractor’s 2005 availability computations must be based upon the 2000 Census for the first time.