On March 15, 2022, the U.S. Department of Labor, Office of Federal Contract Compliance Programs (OFCCP) issued a new directive on pay equity audits to provide “guidance on how OFCCP will evaluate federal contractors’ compliance with pay equity audit obligations and clarif[y] OFCCP’s authority to assess and review pay equity audits conducted pursuant to 41 C.F.R. 60-2.17(b)(3).” Among other things, the directive clarifies OFCCP’s authority to require federal contractors to produce internal pay equity analyses during an audit and further takes the position that except in limited circumstances, federal contractors cannot invoke attorney-client privilege or the work product doctrine to shield pay equity analyses from the Department of Labor.
Join us for a 30-minute briefing where NACUA members Monica Barrett (Bond, Schoeneck & King PLLC) and Syma Siddiqui (Johns Hopkins) will summarize the important points of the OFCCP directive and offer practical considerations for undertaking pay equity audits on campus pursuant to this new directive.
This Briefing will be
audio-only, complimentary, and available to all NACUA members.