More Data, More Risk: OFCCP's Approach to Multi-Year Pay Data - 2024 Expert Summit

Originally Aired: February 28th, 2024, as part of DCI's 2024 Expert Summit for Employment Attorneys


With the implementation of the newest scheduling letter and itemized listing, OFCCP is requiring significantly more pay data at the start of each audit. With this increase in data OFCCP can analyze, the risk to contractors undergoing reviews also increases. In this session, Lisa Harpe and Jana Garman discuss: 

  • The risks that are introduced by larger datasets that are aggregated over time periods 
  • OFCCP's methodology in analyzing the compensation data it requests at the start of an audit 
  • Risk mitigation tactics when preparing for an audit



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