Four plus one take-aways from 12/12/2014 Houston OFCCP Presentation
1. Impact Ratio Analysis (IRA) is still important to the OFCCP’s workforce analyses. The 80% rule is still a tool. However, the current compliance manual requires that a more holistic approach using statistical analysis and the calculation of standard deviations, be used in the final analysis and during the investigation.
2. Ethnic and sub group analysis is becoming more and more important. The diversification of the U.S. workforce is creating a situation where smaller racial or ethnic groups are now large enough to study (2% rule)
3. Pre-Employment background checks can be used with care. Employers should ensure that criminal history checks are germane and relevant to the jobs at issue. Guidance on credit history checks is expected in the coming months.
4. Military Vet. goals and more guidance are expected in March 2014. Some guidance was provided in 2013.
Plus one take away…
It is amazing how far and wide the concepts of statistical significance have traveled over the last 20 years. The OFCCP compliance officers were conversant in the concepts as well as small and large sample ratio statistical tests. 20 years ago these concepts were just making there way out for public consumption.
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