New regulations, a new scheduling letter, and new compensation discrimination investigation protocols have fundamentally changed how the OFCCP conducts compliance reviews. With the agency “steering” their investigative strategies in new directions, federal contractors and subcontractors need to rethink the way they examine affirmative action compliance. This presentation will identify common problems that contractors face in audits so you can make changes now. You will learn:
· What to expect if you receive an audit letter, including the latest OFCCP audit trends
· How OFCCP is enforcing the new 503 and VEVRAA requirements
· The toolbox OFCCP currently uses to investigate differences in employee pay
· Whether “steering” is a placement or compensation problem and how to identify whether your company
is at risk for a steering claim
· How to respond if OFCCP asks for a “compensation interview”
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Lynn Clements
Director of Audit & HR Services
Berkshire Associates, Inc.
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As Director of Audit & HR Services for Berkshire Associates Inc., Lynn A. Clements oversees Berkshire’s audit defense, pay equity and advanced people analytics practice. Throughout her career, Lynn has provided clients with strategic insight and practical compliance and risk management advice in hundreds of government investigations, including OFCCP compliance reviews and EEOC investigations.
With over 20 years of experience, including serving in high level policy positions at both the Office of Federal Contract Compliance Programs (OFCCP) and the Equal Employment Opportunity Commission (EEOC), Lynn is a regular presenter of management and employee training at all levels of organizations and has testified before Congress regarding EEO and pay equity issues. Lynn is a frequent presenter at national events, including the 2021 NILG, where she spoke about focused reviews, promotional practices, and was featured on a panel. She has also spoken at several local ILG meetings in 2021, including Charlotte, Ohio, Philadelphia, Orange County, and more.