Lessons Learned from Current OFCCP Compensation Reviews
Identifying potential disparities in compensation remains a top priority for OFCCP. But most organizations have a limited understanding of what OFCCP is looking for when it reviews a contractor’s compensation practices during a compliance review.
In this presentation Lynn Clements, Esq and Dr. Thomas Carnahan talk about what they do best -- navigating the pay portion of an OFCCP compliance review – and share practical tips on how organizations can protect themselves against potential risk. Lynn, a former senior official at OFCCP and EEOC, and Thomas, an industrial/organizational psychologist, will discuss their experiences helping employers explain and defend their compensation practices during recent OFCCP compliance reviews across the country. The panel will provide insights on the types of questions OFCCP has asked contractors and what contractors can expect from
OFCCP statisticians reviewing their data. Attendees will leave this session with a list of practical take-aways, including ways to comply with the requirement to annually review your organization’s compensation systems as part of your annual affirmative action program, how to evaluate current risk, and what organizations can do proactively to prepare for OFCCP’s review of pay practices.
Learning Objectives:
- How to comply with the requirement to annually review your organization’s compensation systems as part of your annual affirmative action program
- How to evaluate current risk
- What organizations can do proactively to prepare for OFCCP’s review of pay practices
Lynn Clements
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.
Thomas J. Carnahan, Ph.D
Thomas Carnahan, Ph.D is the Pay Equity Manager and is responsible for managing Berkshire’s pay equity line of business by promoting the ability to conduct meaningful, statistical analyses of clients’ compensation data to ensure fair pay and in support of federal, state, and/or local fair pay laws. With more than 15 years of experience in research methodology, data analysis, and HR process development, Thomas brings to Berkshire advanced-level data capabilities, and an extensive background that will serve to enhance our pay equity solutions. Thomas holds a Ph.D in Industrial/Organizational Psychology from Capella University and a Bachelor of Arts in Psychology from Western Kentucky University.