Compensation Systems Analysis

Compensation systems analysis continues to be an extremely important issue in OFCCP compliance evaluations. The time to audit and assess company compensation pay practices is now.   Your compensation systems should be reviewed at least once a year and well in advance of an OFCCP compliance evaluation so that corrective actions can be addressed.

THOMAS HOUSTON assists its clients with this annual requirement by including a Comparative Salary Report (CSR) in our Affirmative Action Plan Services Package as a starting point to assist organizations in conducting a compensation equity analysis. THOMAS HOUSTON offers several other types of independent compensation equity analyses upon request.

2017 EEO-1 Reporting W-2 Pay Data No Longer Required!

Employers were originally required to add W-2 Pay Data to their 2017 EEO-1 filing with a filing extension date of March 31, 2018 until the Office of Management and Budget's Office of Information and Regulatory Affairs (OMB/OIRA) called for a review and stay on the implementation on August 29, 2017. This stay is not a repeal of the regulation itself, but a stay on implementation. Among OMB/OIRA's concerns was that the new compensation data collection was unnecessarily burdensome, lacked practical utility, and that data privacy and confidentiality issues raised had not been adequately addressed. The EEOC will be required to submit to OMB a new information collection package for future EEO-1 form revisions. During this time of review, it is possible that the revised EEO-1 filing will be modified to be less burdensome on employers, while enhancing confidentiality and privacy safeguards. Clients are advised to review their HRIS capability to generate compensation data and hours worked in various formats and time frames.

Although the W-2 Pay Data is no longer required to be filed with the 2017 EEO-1 Report, the filing deadline date will remain March 31, 2018.

Organizations should consider reviewing their compensation data in lieu of the stay to identify any pay disparities in their compensation programs. THOMAS HOUSTON has created “preview” reports that would utilize your latest W-2 Pay Data to highlight the disparities to address.

Our exclusive EEO-1 Filing/Summary Compensation Data "Preview" Reports can be run for each of your EEO-1 establishments and consolidated workforce, analyzing your data by both EEO-1 category and EEOCs 12 proposed pay levels within. Additionally, the "Preview" Reports will be run using annualized rates/pay levels derived from hours worked for each EEO-1 category and 12 proposed pay levels. These reports can be used to identify possible data integrity issues and provide your organization with analysis and results to be used to correct any identified issues. Current THOMAS HOUSTON EEO-1 reporting clients will receive a 5% discount on the EEO-1 Filing/Summary Compensation Data "Preview" Reports.

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Compensation Evaluation Services

Compensation analyses have become extremely important issues for all employers – but especially employers who hold Federal contracts and subcontracts. The time to audit and assess company compensation pay practices is NOW! THOMAS HOUSTON has redoubled efforts in this area and developed useful tools for companies to utilize when reviewing all forms of compensation.

  • A Base Pay Comparative Salary Report analysis should be performed well in advance of an OFCCP compliance evaluation and corrective actions implemented where necessary. This analysis is included with our Affirmative Action Plan packages, but available as a stand-alone package for all employers.
  • Bonus Comparative Salary Report analyzes annual bonuses awarded during the reporting period.
  • Total Cash Compensation Comparative Salary Report aggregates all of the compensation information currently required by DOL/OFCCP with AAP submissions.

Specialized Consulting Services

Our THOMAS HOUSTON compensation partner, Jude Sotherlund, brings unique expertise to compensation analysis and review, corporate management compliance evaluations, diversity and other human resource management issues and training. Jude is an expert in monitoring all forms of remuneration for nondiscrimination, and is a frequent speaker on issues surrounding equal pay, fair pay and nondiscrimination.

Consulting services can be provided individually or packaged at the client's request:

  • Analysis of Performance Management System(s)
  • Annual Merit-to-Performance Analysis
  • Compa-Ratio Analysis
  • Analysis of Starting Salaries
  • Analysis of Long-term Incentive Programs, Benefits and Perquisites