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CELEBRATE DIVERSITY MONTH
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Affirmative Action Services
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Plan Preparation (OFCCP/FTA)
Compliance Evaluations
Audit Representation
Compensation Evaluation
Interim Reporting |
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Compensation Evaluation Services
The Comparative Salary Report (CSR) as referenced in the article on the right, is the starting point to assist organizations in conducting a compensation equity analysis. THOMAS HOUSTON associates, inc. offers client-specific specialized consulting in the area of compensation including the performance of an independent compensation equity analysis for your organization.
Understanding the complexities of differentiating amongst peers, THOMAS HOUSTON can work with each client to refine the data analyses utilized in the OFCCP's broad-brush approach. Our analytical compensation services include regression analyses; pooled compensation analyses by jobs of similar scope; bonus analyses (by bonus program); and, analyses of total cash compensation.
For those clients desiring a more robust approach (proactively or reactively), our compensation team has the professional capacity to cull through HRIS databases, personnel files, historical documents, etc. and provide a longitudinal analysis by employee and diagnostic of findings. We also work with clients to produce analyses to meet their specifications including analyses of performance management system(s); annual merit-to-performance analyses; compa-ratio analyses; analyses of starting salaries for volume hiring by hiring "class", (i.e., MBAs, college/university graduates, etc.) or by title (i.e., Customer Service Representative I, etc.); as well as analyses of long-term incentive programs, benefits and perquisites. These services can be provided individually or packaged at the client's request.
For more information or to receive a quote for these consulting services, please contact our Sales Team at (800) 330-9000 or email us at info@thomashouston.com |
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Equal Pay for Equal Work
President Obama marked the 19 th National Equal Pay Day by issuing his annual Presidential Proclamation and moved the day itself from a date surrounding April 15 th (when Federal income tax filings are due) to April 8 th - the date that the President stated a woman would have to work in the new year to earn what a male earned the year prior. Equal Pay Day, begun in 1996 by the National Committee on Pay Equity (NCPE) is an annual grassroots awareness campaign to highlight the wage gap between men and women wage earners.
The President also issued a Presidential Memorandum to the Secretary of Labor entitled, "Advancing Pay Equality Through Compensation Data Collection." Though the Memorandum has no immediate affect upon Federal contractors, it may in the near future. Specifically, the Presidential Memorandum states that the "lack of sufficiently robust and reliable data on employee compensation, including data by sex and race" is impeding effective enforcement of the Equal Pay Act of 1963; Title VII of the Civil Rights Act of 1964; and Executive Order 11246.
The President directed Secretary of Labor, Thomas Perez, to propose a new rule within 120 days to better screen Federal contractor employee compensation data in order to better direct the agency's enforcement efforts "toward entities for which reported data suggest potential discrepancies in worker compensation, and not toward entities for which there is no evidence of potential pay violations".
The Presidential Memorandum stated that rule should be based upon the comments received in response to the agency's Advanced Notice of Proposed Rulemaking (ANPRM) published August 10, 2011 in the Federal Register. That ANPRM requested comments in 15 broad areas ranging from the type of additional compensation data relevant for collection (i.e., annual pay increases, bonus information, perquisites and benefits, total compensation) and the timing of such reporting; to the proper analytic methods/tools to use in the future.
Clients are reminded that there is an affirmative action obligation at present to review compensation for non-discrimination on a regular/routine basis. Review of THOMAS HOUSTON's Comparative Salary Report (CSR) which accompanies each Affirmative Action Plan (AAP) is one method for doing so.
Additionally, the President signed into law an Executive Order explicitly prohibiting Federal contractors from retaliating against employees who inquire, disclose or discuss their compensation in the workplace. The Executive Order states that ensuring that the "employees of Federal contractors may discuss their compensation without fear of adverse action will enhance the ability of Federal contractors and their employees to detect end remediate unlawful discriminatory practices...." Secretary Perez is required to submit regulations to implement the requirements of this Executive Order within 160 days.
THOMAS HOUSTON will follow these issues closely and provide updates as needed. |
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FAQ
Q. Do other laws also prohibit pay discrimination? A. Yes, all of the laws enforced by the EEOC prohibit pay discrimination. Pay discrimination based on sex is also prohibited by Title VII of the Civil Rights Act of 1964. Title VII prohibits discrimination in compensation and other terms and conditions of employment, so it is broader than the EPA. Title VII also prohibits discrimination in compensation or other aspects of employment based on race, color, religion, or national origin. The Age Discrimination in Employment Act, the Americans with Disabilities Act and the Genetic Information Nondiscrimination Act prohibit discrimination in compensation or other aspects of employment based on age (40 or over), disability, or genetic information. |
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CELEBRATE DIVERSITY MONTH | |
April marks the beginning of new experiences and new transitions, being the first full month of Spring. April is also Celebrate Diversity Month. Diversity is narrowly defined as recognizing the collective mixture of individual differences and similarities in people. It extends well beyond race and gender. It's based on recognizing, appreciating, and valuing the unique talents and contributions of all individuals. Celebrate Diversity Month, started in 2004 to recognize and honor the diversity surrounding us all. |
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This information is intended to be informative
and should not be considered legal advice on any specific matter |
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Metropolitan Washington, DC
703.481.9839 | www.thomashouston.com |
Ft. Lauderdale, FL
954.916.9290 |
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