At the conclusion of the desk audit, the CO must notify the contractor in writing of the general nature of any preliminary compensation disparities that warrant further information requests or on-site review. For example:
- Compensation issues for women in the Engineers and Project Architects SSEGs.
- Compensation policies and practices for the Engineers SSEG for Blacks and Hispanics, and the Technicians SSEG for females.
When conducting further review of a contractor’s compensation practices, the CO must seek additional information to understand the contractor’s compensation system, the elements that drive compensation decisions, and the job structure/hierarchy. Based on these facts, the CO may broaden or narrow the SSEGs and subsequent data requests to conform the analysis closely to the contractor’s compensation system and practices, where appropriate. Chapter 2 contains information on conducting a further review of potential compensation discrimination.74
74. See Directive 2018-05 for compensation modeling guidance beyond the desk audit.