Text "steering" with a red X. Steering could lead to penalties in an OFCCP auditWhile there has definitely been an emphasis in audits on analyzing compensation in recent years, we are now seeing OFCCP take some additional steps with regard to how they are looking at your compensation. In past years, as a result of reviewing summary compensation data provided by the contractor, the focus of the compensation aspect of an audit was identifying differences in pay by job title affecting females vs. males and minorities vs. non-minorities. While the OFCCP still uses this method to review contractors’ compensation, we are seeing that they are also identifying potential compensation problem areas as a result of steering and promotion issues.OFCCP’s additional approach to looking at compensation:When the OFCCP identifies potential steering and promotion issues in an audit, they will look to determine whether there is an impact on your compensation. The potential issues may take the form of differences in pay by job title based on the representation of females vs. males and minorities vs. non-minorities and/or differences in opportunity for advancement within a line of progression. As an example, if there is a high concentration of females in a particular job title and an underrepresentation of females in another job title within the same job family (where similar experience and/or education is required), and the pay and/or opportunity for growth is different, this would become a focus area in an audit. Men-women-graph-affirmative action programHow contractors can protect themselves:The way to protect against this type of scrutiny in an OFCCP audit is to be diligent in the internal audit of your personnel processes, including a review of applicant and hiring activity, promotion activity, and training opportunities designed to prepare employees for upward mobility. If your review reveals any indication of steering and promotion issues which have an impact on compensation, it is in your best interest to resolve the problems before you submit any data to the OFCCP for an audit.Contact Career Resources if you have questions about steering issues in your workplace at info@crincorporated.com