Fostering Pay Transparency In Your Organization

In case you missed it, as a Federal Contractor, you and your company are obligated to foster pay transparency by letting  your employees know their rights under the Pay Transparency Nondiscrimination Provision.   At a minimum you are required to include the provision in employee manuals and handbooks as well as post with other employee rights information.  The following is copied directly from the Department of Labor’s website and provides guidance to your obligations.

Office of Federal Contract Compliance Programs (OFCCP) 

Pay Transparency Nondiscrimination Provision

Every employer covered by Executive Order 11246, as amended, is required to post the Pay Transparency Nondiscrimination Provision and include it in employee manuals and handbooks. The provision provides applicants and employees notice that the employer will not discriminate against them for inquiring about, discussing or disclosing their pay or, in certain circumstances, the pay of their co-workers.

Because OFCCP believes that uniform use of the nondiscrimination provision is necessary to ensure consistency and clarity in the information provided to applicants and employees, contractors must, at a minimum, use the language provided in the nondiscrimination provision provided below to satisfy both dissemination requirements. Of course, nothing limits a contractor from providing additional information to their employees about their rights and obligations.

Posting Requirement

The posting requirement may be accomplished by posting the provision electronically or by posting a copy of the provision in conspicuous places available for employees and applicants. In order to facilitate the implementation of this requirement, OFCCP has created two versions of the nondiscrimination provision.

The first version is formatted to be posted electronically or printed and posted on the employer’s premises. It includes the OFCCP logo and contact information.

The second version includes the required, prescribed language only without formatting. At a minimum, contractors must use this prescribed language.

Employee Manuals and Handbooks

In addition to the posting requirement, employers covered by Executive Order 11246 must incorporate the nondiscrimination provision into their existing manuals or handbooks. Again, employers must, at a minimum, use the unformatted version.

Please note that this page provides general information. It is not intended to substitute for the actual law and regulations regarding the program described herein.

Note from Biddle:  Ensuring pay equity is a social and legal concern.  If you have potential concerns about pay equity in your organization or would like to know more about conducting a pay equity study, please feel free to give our experts a call or join us at the BCGi Summit where we will be diving into the intricacies of compensation (pay equity) analysis.

UPDATE: OFCCP’s Disability Self-ID Form Approved for 3 Years

UPDATE (02/01/2017):

As an FYI, the OFCCP is stating that, although the new form should be used starting today, because of systems changes, etc., you will have 10 days to implement the new form.  No changes were made from the last form other than the date for approval (1/31/2020).  Make sure your ATS and onboarding are using the new form.

ORIGINAL POST:

In case you missed it, the OFCCP announced today that the OMB (Office of Management and Budget) released a new disability self-I.D. form. Federal Contractors need to start using the new form immediately.

This form is to be used when soliciting applicants at the pre-offer (applicant stage) and post-offer (on boarding) stage, as well as to survey your workforce for Disability status every five years.  This has been the case since the VEVRAA and 503 regulation changes came into effect as of March 2014.

The only change made to the form is a new expiration date.  In short, this form replaces the Disability Self-I.D. form that Federal Contractors have been using to obtain Disability Status of their applicants.

For additional assistance with Disability reporting, please reach out to Biddle Consulting Group:

(800) 999-0438 or staff@biddle.com

Resource (PDF): New Disability Self-ID Form

Early-Bird Discount – 2nd Annual BCGi Summit

bcgi-summit-logo-250x792nd Annual BCGi Summit
Managing Uncertainty: EEO in a New Administration

Early-bird registration is still available for the 2017 BCGi Summit. Biddle Consulting Group’s experts partner with leading industry experts to deliver a variety of EEO Topics during this one and a half (1.5) day conference.

2017 BCGi Summit Details:

  • When: April 6-7, 2017 (Bonus Pre-Conference “Ask The Experts” Sessions: April 5)
  • Where: JW Marriott San Francisco Union Square (San Francisco, CA)
  • Registration Fee: $695 (Early Bird Discount – Save $100, if you register by February 28, 2017)

Session Topics:

  • Insight From The Inside: Former OFCCP Staff Speak Out
  • Exploring The Future Of Compensation Equity: Lessons From The California Fair Pay Act
  • The Unseen World of Implicit Bias: How To Identify It And What To Do About It
  • Big Questions – Big Data: How Advanced Analytics Shed Insight Into EEO
  • Recruiting And Retaining Individuals With Disabilities: Tools & Techniques That Work

Spring Into Action!

National Disability Employment Awareness Month – October 2016

National Diversity Employment Awarness Month NDEAMOctober is NDEAM, at the Department of Labor – National Disability Employment Awareness Month, which “celebrates the contributions of workers with disabilities and educates about the value of a diverse workforce inclusive of their skills and talents.”

The goal is to educate companies of NDEAM, which dates back to October 1945 when it was originally named National Employ the Physically Handicapped Week.

However, the history of government intervention in rehabilitating individuals with disabilities goes back even further than 1945, unsurprisingly, to World War I. The 1917 Smith-Hughes Act, 1918 Soldier’s Rehabilitation Act, and more substantially, the 1920 Smith Fess Act came out of combat related disabilities and an effort to rehabilitate soldiers. However, the Smith Fess Act also provided assistance for non-war related disabilities.

The NDEAM website gives examples of how employers can educate their managers and employees to create a more inclusive workplace by mentoring, advertising their involvement in NDEAM through social media, and many other ways.

Visit the website to discover ideas that you can use in your organization and document as part of your Diversity and Inclusion efforts: https://www.dol.gov/odep/topics/ndeam/index.htm.