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OFCCP’s Revised Compensation Directive (Podcast)


In this podcast, Lauren Hicks, Leigh Nason, and Scott Kelly discuss Directive 2022-01, which the Office of Federal Contract Compliance Programs (OFCCP) revised and renamed on August 18, 2022. The speakers cover how the new directive, which amends the agency’s guidance suggesting that federal contractors must perform annual pay equity audits to comply with affirmative action programming (AAP) regulatory requirements, walks back language regarding the documentation required to demonstrate compliance with compensation analysis obligations. The speakers also discuss how the revised guidance imposes new burdens for contractors and offer insights into the reasons fueling the agency’s changes regarding conducting compensation analyses and evaluations.



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