Attorneys Analyze OFCCP Proposal Requiring Equal Pay Report Submissions

Bloomberg BNA:

Under the OFCCP’s Equal Pay Report notice of proposed rulemaking, what would be required of federal contractors and subcontractors?

Littler:

Contractors would have to determine whether they have a filing obligation, in the first place. For direct contractors, this is likely to be less burdensome than if the company is a subcontractor, but it still could raise legal issues for companies that have many subsidiaries—not all of which prepare affirmative action plans or believe they are subject to OFCCP’s jurisdiction.

Contractors then would have to preserve the workforce snapshot for each location for which an EEO-1 report was ...