By signing the National Defense Authorization Act (“NDAA”) on December 31st, President Obama dealt a blow to the OFCCP’s determined effort in gaining jurisdiction over the healthcare industry. For more than a decade, the OFCCP has been fighting, and seemingly winning, the battle to claim that healthcare facilities are considered subcontractors and are therefore subject to compliance under Executive Order 11246, Section 503...

Should Federal contractors be proactively analyzing pay during this time of transition at OFCCP? For more than a decade the Office of Federal Contract Compliance Programs (OFCCP) has been talking to the Federal contractor community about Pay Equity enforcement. OFCCP was giving presentations about how statistical analyses, particularly multiple regression, was going to become a part of regular audits at Industry Liais...