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A Special Interview With OutSolve Principal and Lead Consultant Jeremy Mancheski

Scott Kushner

Topic - New EEO-1 Compensation Reporting

Why is this the time for contractors to start thinking about these regulations?

“2017 is too late. You want to think about this now. Right now, there is no regulatory requirement, however, we have a peek into what the EEOC and OFCCP intend to do. So, let’s do some preliminary analyses. Let’s take a look at your organization. With enough time, we can be prepared to make any changes, in case the requirements take hold in 2017.”

Is the government going to be analyzing the data we provide them?

“The Q&A for the proposal adding compensation to the EEO-1 report says specifically that EEOC and OFCCP intend to use this to affect change. It’s very clear there will be an analysis, which is a significant departure from the current EEO-1 report which gives no real insight to the government.”

What benefit is there to proactively getting into compliance?

“An ounce of prevention is worth a pound of cure. If you wait until 2017 for this to be required, then you don’t have any ramp-up time to affect change or do any kind of preliminary analysis. By doing it now, it can be protected via attorney-client privilege since it’s not a legal requirement at this point. So, you have a full year to make changes within your organization to be fully prepared when the formal request comes in.”

What has OutSolve done to prepare for these new regulations?

“We prepare EEO-1 and VETS 4212 reports for the large majority of our customers. This is a natural extension of our services, as we also prepare compensation analyses. We will, no doubt, offer this as an add-on service once it’s required. But in 2016, we have a real opportunity to offer a solid package of analysis preemptively to our clients, in anticipation of everyone being required to do this a year later.”

Do you anticipate this will affect audits and audit preparation in any way?

“If OFCCP were able to have a proverbial smoking gun with regard to your company’s compensation, prior to selection of an audit, that gives them a unique weapon. They can run an array of metrics and certain analyses that will highlight who the worst offenders are. In fact, that was their attempt at the turn of the century with the EO survey. It never came to pass because we had a change of administration that pulled focus away from compensation. So, the previous administration couldn’t get the job done. Now, times have changed and OFCCP is going back to compensation and has an excellent opportunity to draw more data and information from a wide swath of contractors than ever before.”

How does this change the dynamic of the EEO-1 report?

Previously, and currently, the EEO-1 is a two dimensional tool for selection. This compensation report adds a third dimension and a real, dynamic arrow in the OFCPP’s quiver. It is a drastic difference. All contractors should be aware of the potential consequences before handing over this additional information to the agency. We are here to help.

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