OFCCP Issues ANPRM on Compensation Data Collection Tool

In today’s Federal Register, the OFCCP issued an Advance Notice of Proposed Rule Making (ANPRM) for a new Compensation Data Collection Tool.  The Agency is seeking comments on the following questions:

  1. What data or information should be collected in order for OFCCP to assess whether further investigation into the contractor’s compensation decisions and policies is necessary?
  2. By what set of job categories should the data referred to in question (1) be collected?
  3. What elements of compensation should be collected?
  4. Is there a set of questions that would capture information that would be helpful in understanding a contractor’s compensation system, such as policies relating to promotion decisions, bonuses, shift pay, setting of initial pay, etc.?
  5. What type of compensation trend analyses would be appropriate to conduct on an industry-wide basis?
  6. What specific categories of data would be most useful for identifying contractors in specific industries for industry focused
    compensation reviews?
  7. What specific categories of data would be most useful for conducting compensation analyses across a contractor’s various establishments?
  8. Practical concerns contractors may have regarding responding to the compensation data request and how contractors currently record and maintain compensation data
  9. What specific categories of data would be most useful to contractors interested in conducting self-assessments of their compensation decisions
  10. What were the strengths and weaknesses of the compensation section of the 2000 EO Survey?
  11. What factors should OFCCP take into consideration if require contractors to submit data electronically?
  12. What are the benefits and drawbacks of requiring businesses that are bidding on future Federal contracts to submit compensation data as part of the Request for Proposal process?
  13. Should OFCCP decide to expand the scope of the compensation data collection tool beyond supply and service contractors to include construction contractors, what factors or issues particularly relevant to such contractors should OFCCP keep in mind
    when designing and implementing the tool?
  14. Are there other constructive suggestions for the design, content, analysis, and implementation of a compensation data collection tool?
  15. In response to this ANPRM, OFCCP encourages small entities to provide data on how they may be impacted by the requirement to provide the compensation data requested by the new data collection tool.

Comments are due October 11, 2011.