OFCCP audit support leading to successful early resolution

When a Fortune 100 technology manufacturer was involved in a major acquisition, CRA validated data from 14 data sources to assess risks in existing salary, bonus, stock grants, and on-target earnings. CRA supported over 20 Office of Federal Contract Compliance Programs (OFCCP) audits validating employee-level compensation data and helped produce supplemental data requests. In several advanced audits, CRA participated in in-person conciliation meetings with the Agency. Ultimately, the contractor came to an Early Resolution Conciliation Agreement with OFCCP, exempting them from audits for five years.

CRA was then engaged to assist the contractor as they transition from traditional establishment-based AAPs to functional AAPs. CRA collaborated with the contractor to arrive at a logic that balanced multiple objectives: define groups that are useful in administering diversity efforts, minimize risk and false positives identified in routine pay analyses, and propose a structure that OFCCP would accept. OFCCP accepted the structure as proposed by the contractor.

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