Wednesday, August 13, 2014

EEO-1 and VETS 100A Filing Deadline

What a busy time of year this is! The end of summer and back to school. Many clients are nearing the end of their fiscal year or are working on their AAP data. This is also annual report time for federal contractors.

Both the EEO-1 Survey and VETS 100/100A Contractor Reporting systems are open. Federal contractors are required to file EEO-1 and VETS 100/100A reports if they meet the requirements. In the event of an OFCCP audit you should expect to be asked to provide copies of your reports. Kairos Services is here to help. We can review your reports and compare them to your AAP for consistency in reporting.

Friday, August 8, 2014

DOL Releases Proposed Rule to Collect Annual Compensation Data From Federal Contractors and Subcontractors

Yesterday the U.S. Department of Labor issued a proposal to collect summary data on how federal contractors and subcontractors pay their employees. This Notice of Proposed Rulemaking will be published in Friday's edition of the Federal Register and open for public comment from August 8 - November 6, 2014.

This could have a significant impact on your Company's workload and the results of compensation findings during OFCCP audits. We encourage our clients to read the proposed rule when it is released and submit comments. Below is the press release announcing this action. More information on the NPRM and how to comment can be found at

Thursday, August 7, 2014

How will Companies be selected for audits? Compensation!

No sooner did we think the new regulations for individuals with disabilities and protected veterans were the game changers; we find that OFCCP is moving toward creating a new day for compensation analysis for federal contractors and subcontractors. A review of the Conference Agenda at the ILG National Conference in Washington, DC, this week shows a multitude of workshops devoted to compensation. From Compensation 101 to How to Investigate Compensation Disparities to Equal Pay Enforcement to Moving Beyond Regression, there are plenty of compensation workshops for practitioners to select from. DOL's stunning Press Release announcing the proposed rulemaking which intends to require annual reporting to OFCCP by federal contractors and subcontractors of their workforce's compensation in the midst of the conference caused quite a stir.

OFCCP intends to use this annual compensation reporting for selecting federal contractors and subcontractors for audits. Basically, those companies who submit compensation reports reflecting potential disparities will be at higher risk of being selected for an audit than those companies who do not. Furthermore, submission of this data on an annual basis potentially limits the amount of adjustments that can be done internally upon receiving an audit letter, since contractors will then have to show OFCCP support regarding any changes made. This data collection could include very detailed information such as copies of W-2 information.