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Pay Transparency - Tips for Training Managers


Debra Milstein Gardner authored Pay Transparency - Tips for Training Managers in the July 2016 publication of the OFCCP Digest.

On January 11, 2016 the Pay Transparency Final Rule amending E.O. 11246 went into effect prohibiting federal subcontractors and contractors from disciplining or discharging employees or applicants for discussing, disclosing or inquiring about their pay or that of other employees or applicants. An exemption exists for applicants and employees who make the disclosure based on information obtained in the course of performing their essential job functions. Contractors modifying or entering into a new contract on or after January 11, 2016 are covered.

Since it is over six months since the Pay Transparency Rules went into effect, I’ve been wondering about the communication and implementation strategies undertaken by government contractors. Even though there is no requirement in the Rule to conduct training, it is a proactive approach to ensuring that your management team understands the nuances of the Rule.

If you have conducted management training covering the new Pay Transparency Rules, you have probably experienced what I have noticed in my presentations. Since I love those tough managers, always questioning and challenging, I knew that training on the topic of pay transparency would be fun! As soon as I communicate what managers cannot do to applicants and employees who talk about their compensation, I notice that the managers’ initial reaction of shock slowly turns to anger. As we delve deeper into the definitions of compensation and compensation information, horror prevails and the accusations that the government is interfering in the way that contractors operate enter into the mix.