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pensation self-evaluation with at the direction of counsel, and that counsel has advised the contractor that the self-evaluation and results are subject to the attorney-client privilege and/or the attorney work product doctrine. Since OFCCP is not able to assess whether contractors who opt for this certification alternative have complied with the Guidelines, OFCCP will perform its own analysis of the compensation practices without regard to the contractors' self-evaluation.
Interestingly, this certification option is voluntary and contractors can produce compensation analyses under the protection of attorney-client privilege and/or the attorney work product doctrine whether or not they have certified their compliance with the regulations.
Yocom & McKee, Inc.'s Complete AAP version 9 software currently produces several salary reports that help contractors evaluate their compensation practices.
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1. The Salary Analysis report reports "Mean" and "Median" salaries Company-wide, by Department, Job, Job Group, EEO Category, or Salary Grade.
2. The Salary Summary Report is a helpful response to Item 11 of OFCCP's audit scheduling letter. It lists employee counts and salary totals by race and gender Company-wide, or by Department, Job, Job Group, EEO Category, or Salary Grade.
3.The Salary Regression Analysis report gives the contractor the ability to analyze compensation practices using a multiple regression analysis. Not intended to be an exhaustive analysis, up to five factors affecting compensation can be tested.
We are working on a new, more powerful version of the Complete AAP software that will allow users to analyze their compensation practices by SSEGs. We plan to have this new version, which will
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include the new racial and EEO categories, available early in 2007. SSEGs are a new, somewhat controversial concept in affirmative action and Title VII law. There is little guidance concerning how similar jobs need be to be grouped for comparing compensation. Courts have roundly rejected the concept of "Comparable Worth" which tried to compare different jobs that arguably had similar worth to an organization. During OFCCP audits, our clients have had good success submitting compensation data analyzed by job.
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