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The U.S. Department of Labor’s Office of Federal Contract Compliance Program regularly reviews employment practices at federal contractors for potential discrimination, and when they assess pay equity, they follow a new model developed and implemented by the Obama Administration. Known as Directive 307, this approach assesses systemic issues more thoroughly and addresses a broader range of pay practices and issues. Pam led the development of these new investigation guidelines as well as the agency-wide training program to support them and has now consulted with investigators on many individual audits.
ASSESSING PAY EQUITY MORE EFFECTIVELY AT FEDERAL CONTRACTORS
In 2011, Pam joined the U.S. Department of Labor’s Office of Federal Contract Compliance Programs, and was tasked with developing new investigative procedures for reviewing pay practices at federal contractors to make them more effective at identifying systemic pay discrimination and align them better with existing law. President Obama had asked the White House Equal Pay Task Force to identify barriers to effective federal enforcement of pay discrimination laws, and the Task Force had specifically flagged existing OFCCP guidelines for review and revision. After reviewing current procedures in the field and talking with investigators and stakeholders, Pam worked with OFCCP and DOL leaders to develop new policy guidance published as Directive 307 in 2013. She also spearheaded a program to train every field investigator on effective pay discrimination investigations and provide ongoing technical assistance, working closely with the agency’s statistical experts and labor economist and the DOL Office of the Solicitor. These reforms have significantly improved OFCCP’s ability to identify and remedy systemic pay issues and they provide a useful roadmap to any organization seeking to better understand patterns and trends of pay disparity in the workplace.