Benefits and Compensation, HR Management & Compliance

Pay Transparency Requirements: Are You in Compliance?

By Susan Schoenfeld, JD

If you are a regular reader of hr.blr.com, you know that the Office of Federal Contract Compliance Programs’ (OFCCP’s) final pay transparency rule took effect on January 11, 2016.

As its primary purpose, the final rule protects employees’ inquiries, discussions, and disclosures of their own pay and benefits, and similar employee activities related to the pay and benefits of others if they obtained that information through ordinary means such as conversations with coworkers.

The final rule applies broadly to any business or organization that is covered by Executive Order (EO) 11246 (i.e., holding a single federal contract in excess of $10,000; or multiple contracts with a combined total in excess of $10,000 in any 12-month period).

The pay transparency rule applies to covered contracts entered into or modified on or after January 11, 2016. Contracts will be considered to have been “modified” if they contain any alteration in their terms and conditions, including supplemental agreements, amendments, and extensions.

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