Compensation Analysis

Lighthouse helps contractors perform required annual Pay Equity Analysis. Pay equity simply means that pay should be fair--equal pay for equal work on a group or on an individual basis.

The Office of Federal Contract Compliance Programs (OFCCP) enforces Title VII of the Civil Rights Act of 1964. Title VII prohibits employers from discriminating based on Race, Color, Gender, Religion, or National Origin in employment decisions, including hiring, firing, promotions, training, benefits, discipline, and compensation.

Title VII details two types of Discrimination, Disparate Treatment and Disparate Impact. Disparate treatment is either intentional, defacto discrimination, or a pattern and practice that adversely affect a protected group. Disparate Impact is a practice or practices that adversely affect a group of individuals, even if unintentional. We look for both.

The legal principle for judging if pay is equitable is equal pay for equal work. Recently, OFCCP and some states (notably California) have tampered with that principal by introducing the concept of same or similar work. This begs the question, what exactly is similar enough? Lighthouse Compliance experts help you understand what that means in terms of your workforce.

The OFCCP and EEOC, historically, analyze current pay to determine adherence to Title VII. Accordingly, we look for statistical anomalies among “like” jobs. These anomalies could be construed, by the OFCCP, as Title VII pay discrimination. We also consider individual difference to the extent possible from available information and address possible pay issues arising from the composition of Job Titles.

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