Guide reviews existing regulations and provides best practices for educational institutions
Since releasing the Technical Assistance Guide for Educational Institutions, OFCCP Director Craig Leen has said that colleges and universities can expect compliance reviews to be scheduled beginning in the spring 2020. He also stated that the compliance evaluations should be more efficient than in the past.
Most of what is included in the Guide is not new to contractors. There is a review of current laws and regulations and overview of the components of the AAP. However, there is some education-specific information also. For instance, the Guide addresses the following:
- When an education institution should have a single or multiple AAPs,
- What are appropriate pay analysis groups with respect to tenure track instructors,
- What variables should be included in regression analyses,
- Who should be counted as employees,
- What compensation issues are specific to tenure or tenure-track instructors compared to non-tenure track instructors,
- What is allowed of religious colleges and universities, and
- That “specialty areas” such as athletics, medical, online institutions that may come up in a compliance evaluation.
Directive 2019-05 Contractor’s Obligations Regarding Students in Working Relationship with Educational Institutions.
Directive 2018-03 Religious Exemptions