Woman on a keyboard. OFCCP continues to focus on steering issues for women and minoritiesWe anticipate that the OFCCP will continue to focus on the issue of steering for the next few years.“Steering” refers to the placement of individuals from certain groups (i.e. minorities, females) into specific positions or career ladders, which could potentially lead to less pay and room for growth.OFCCP is concerned with this practice because it ultimately has a negative impact on compensation for these affected individuals. Here is what you need to know about steering and what you should do.Possible misconceptions:Contractors may have a false sense of security with regard to the steering issue if they do not have any areas of underutilization and/or adverse impact has not been identified in their selection practices. While contractors have the tendency to focus on potential placement issues at the job group level, we’ve seen the OFCCP look at placements at a more granular level by looking at each position within each job group including the female and minority representation within each job title.How to determine whether you have potential steering issues:Contractors should pay attention to the minority (as a whole as well as by individual minority group) and female representation of positions that make up their job groups. As an example, an Operatives job group with the majority of the Assemblers being female and the majority of the Production Workers being male would be a red flag to the OFCCP if the Assemblers are paid less than the Production Workers. This could be a potential issue regardless of whether females and/or minorities are underutilized in this job group, and regardless of whether females and/or minorities were adversely impacted in the selection process for these positions.How to address your potential steering issues:If you conclude that you have job titles where it appears as though steering may have occurred, it is important that you analyze your processes (hiring, promotion, and compensation) to determine how individuals were placed into the potentially problematic positions. Any issues you identify need to be remedied prior to an OFCCP audit.If you have further questions about steering issues or how you can analyze your company please contact info@crincorporated.com