1. Go to www.dol.gov/regs/fedreg/notices/2006005457.pdf. Go to page 35120 and find the section with the title Final Voluntary Guidelines-Voluntary Guidelines for Self-Evaluation of Compensation Practices for Compliance With Executive Order 11246 With Respect to Systemic Compensation Discrimination (“Voluntary Guidelines”). There are several steps (procedures) listed. The first step, described in Section I.A, deals with sorting employees into “similarly situated employee groupings.” Prepare a memo that highlights the steps or procedures required in the OFCCP Self-Evaluation Guidelines.
2. Include in your memo your ideas on the resources required for your company to conduct such an evaluation: talent requirements (your estimate of number of people and skills/knowledge required), data access (type of data required for the self-evaluation), timing (your best estimate), and other resources.
3. Based on your professional judgment, discuss in the memo the factors your boss needs to consider (expected value gained, risks to manage, outsourcing, etc.) before undertaking a “Self- Evaluation” project.