In reviewing the contractor’s payroll records, the CO should determine at least three things:
- The number of months of payroll activity to review in order to evaluate progress toward work hour participation rate goals;
- The existence of uniformity in the assignment of employees to various project sites; and
- The equity or lack thereof in allowing or granting overtime and other benefits.
a. Number of Months to Review. Review the contractor’s payroll records for at least a six-month period. This review is to evaluate progress toward attaining work hour participation rate goals for minorities and women in each trade. CO’s must review payroll records to determine the percentage of work hours by minorities and women out of the total hours worked by the contractor’s employees in each trade.
b. Uniformity of Assignment. Evaluate the records to determine whether there is uniformity in the assignment of employees to various project sites (federal and nonfederal; commercial and residential; urban and rural). COs will determine whether certain types of projects pay more than others and, if so, whether women and minorities are provided equal opportunities for assignment to the better paying jobs.
c. Equitable Overtime. Evaluate the records to determine whether overtime, incentives, bonuses and other job benefits (e.g., holiday bonuses, pay advances, loans, and profit sharing) are provided without regard to race, color, or sex.