OFCCP Director Craig Leen said that promotion focused reviews will be “coming next” during a webinar in early July. Leen said, “We are very committed to promotion focused reviews as you heard me say in the past. I do believe that many of our compensation cases are really promotion cases, and that often what we are seeing is a failure to promote individuals, which is impacting their compensation.”

OFCCP will engage in a dialogue with the contractor regarding the definition of a promotion and provide guidance where needed. The agency believes that in promotion focused reviews, government contractors “will be able to remove barriers to advancement and with a particular focus based on the statistics and on the advancement of women of color and people of color generally, minority communities, intersectionality, and generally equal employment opportunity and promotions which apply to everybody.”

Leen said that in his experience, you will see individuals of color or women of color in high positions; however, right below the top positions are a lack of minorities or women of color. He said that individuals with disabilities are also less represented at the higher levels of organizations.

OFCCP will be publishing more guidance in this area.