The supplemental information included with the Advance Notice of Proposed Rulemaking (ANPRM) for the Compensation Data Collection Tool reviews the history of the EO Survey which was designed, in part, to be a tool to predict non-compliance and to promote contractor self evaluation. Ultimately, “it was concluded that the EO Survey had little predictive value as a tool for indicating discrimination or non-compliance”. OFCCP rescinded the EO Survey in 2006.
Now comes the Compensation Data Collection Tool the stated purpose for which is “to provide insight into potential problems of pay discrimination by contractors that warrant further review or evaluation by OFCCP or contractor self-audit. Accordingly, it is envisioned primarily as a screening tool."
The ANPRM request for comments, closing on 10/11/2011, presents 15 questions for response by contractors which give some insight to the intended direction of the screening tool. Some examples:
“OFCCP is exploring the possibility of using the data collected through the tool to identify opportunities for nationwide multi-establishment compensation reviews”
“The data collected through the tool may be used to identify contractors in specific industries for industry-focused compensation reviews. What specific categories of data would be most useful for identifying contractors in specific industries for industry focused compensation reviews?”
Additionally, the OFCCP will conduct web-based and Town Hall listening sessions to provide an opportunity to offer suggestions and recommendations related to the scope, content and format of the data collection tool in the months ahead. THOMAS HOUSTON associates, inc. will monitor and communicate the announcements of these listening sessions.
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