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Constructing and Conducting a

Compensation Analysis

2012 ILG National Conference


Waikoloa, Hawaii
August 28, 2012

Equal Employment Advisory


Council
1501 M Street, N.W. | Suite 400
Washington, D.C. 20005

Presented by:
Chris Gokturk
Jeff Norris

The Equal Employment Advisory Council (EEAC) is a nonprofit


association of private sector employers dedicated exclusively to
the
elimination
of
workplace
discrimination
through
advancement of practical and effective equal employment
opportunity, affirmative action, and diversity programs. The
materials developed for this program and the discussions based
upon them are designed to provide accurate and authoritative
information regarding the subject matter covered. They are
provided with the understanding that EEAC is not engaged in
rendering legal, accounting, or other professional services. For
legal advice or other expert assistance, the services of a
competent attorney or other professional should be sought.

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Seminar Overview
Establishing a Compensation Analysis Process
Preliminary Considerations

Understanding Your Current Compensation


Structure
Data Preparation and Review
Conducting the Statistical Analyses
Understanding Statistical Procedures
Analyzing Compensation Practices
What Compensation Should Be Analyzed?
Analyzing Compensation Beyond Base Pay and
Performance

Considerations in Making Pay Adjustments

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Establishing a Compensation
Analysis Process

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Preliminary
Considerations

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Purpose of Analysis
Narrow
Scope
Reactive
OFCCP Review

CSAL List
Proactive
2012 Equal Employment Advisory Council

Expanded
Scope
Litigation/
EEOC Charge
Proactive
Analysis in
anticipation of
litigation
2012 ILG National Conference | August 28, 2012 |

OFCCP Review
Evolving landscape
Focus on current compensation
Initial scope still USUALLY
limited to base pay
Follow up request includes
beyond base pay dollars

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Contractor Selection
Advance Notice Letter
(CSAL)

Still responding to a potential


review
May have additional time to
analyze data or expand scope
as warranted
Ability to address issues PRIOR
TO receipt of scheduling letter

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Litigation or EEOC
Charge
Must stem from or be reasonably
related to charge
Focus on defending the data and
practices in effect during the
alleged time period
Questions:
What is the alleged time period?
What practices are being challenged?

These may alter the scope of your


analysis

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Proactive Analysis
More options available, so
determining scope becomes
trickier
Scope of analysis can be defined
more broadly
Limitations usually data-related
Counsels involvement is critical

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Purpose of Analysis
The companys motivation to
conduct the analysis impacts
Which types of pay practices to
include
Time period of analysis
Whom to include in the analysis
Roles and responsibilities
more on these later

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Getting Started
Where to start
Your Compensation Department
What analyses are currently being
performed
Evaluate appropriateness for THIS purpose

Base or total compensation


Employee groupings
Do you have a compensation structure in
place? What is it?
How is pay determined?
What influences what each employee gets
paid?

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Understanding Your Current


Compensation Structure

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Understanding Your Current


Compensation Structure
What do you say that you do
Compensation philosophy
Compensation structure
Grades, bands, other

Company policies and procedures


Both formal and informal

How does it work in practice

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Understanding Your Current


Compensation Structure
Four keys to minimizing risk
Alignment of policy and practice
Data integrity
Transparency
Monitoring and analysis

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Data Preparation and


Review

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

The KeyEmployment
Data
Preparing data for analysis
Annualizing compensation for your parttimers
Does everyone have a race/gender code
Does everyone have data in the fields that
matter
Review for any garbage in data fields

Any field important enough to


determine or influence pay is important
enough to check for accuracy

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

The KeyEmployment
Data
What data do you need
Groupings and factors that
influence pay
Fields that define THE JOB
Fields that define where the
person sits organizationally
Fields that differentiate an
individual from others in the
same type of job

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

The KeyEmployment
Data
What do you have in your system
How reliable are the data in the fields
Common data integrity issues:
System conversion issues
Example: Everyone has same time in
grade date

Fields that are not kept up to date


Example: Education data

Fields that are important but not


tracked
Example: Prior experience
2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Dates
Check for accuracy and incomplete
values
Legacy System Problems:
Senior employees: hire date is not
actual mark or change date
Errors in updating

Decision date vs. Effective dates


Rehires how handled
Missing parts of dates (e.g., no day)

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Unexpected Data Values


Inconsistent or misspelled text entries
Missing values:
Identify the cause
Have you merged the data correctly

Dont mix with zero values or No entries


Beware of conducting analysis only on the employees with
available data

Outliers or misclassified employees:


Unidentified demotions
Erroneous entries

Wide ranges in pay or grade values for given job title

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Using the Right Data


General pay factor coding schemes:
Yes/No Convert to Dummy/Indicator Factor (0=No, 1=Yes)
Multiple Category Factors: Use as scale or separate factors
Ex: Education level (<HS, HS, BA/BS, MS+Phd) = > 3
factors
Determine reference group and code dummies for
others
Continuous Factors (e.g., experience) plot it by salary
and structure factor appropriately
Correlated Factors try to identify distinct components
E.g., time in company and time in job => time in job and
time in company beyond the current job

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Conducting the Statistical


Analyses

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Understanding
Statistical Procedures

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Topics
Statistical test
Mean/Median Analysis
t-Test
Regressions
Examples of regression plots and
results

Using the right statistical tool


Using the right data
2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Mean & Median


Mean Analysis

What is it?

The average or mean is another way of describing the mid point


of a group of salaries being analyzed. The average is computed by
adding the salaries in a grouping and then dividing their sum by
the number of salaries

The OFCCP is using means for the preliminary review and in


comparing groups that are too small to run a regression
analysis on

Median Analysis

What is it?

The median is one way to describe the mid point of the group of
salaries being analyzed

Useful because it is not affected by very high or very low


salaries

In the past has been heavily used by the OFCCP

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

t-Test
What is it?

The t-test assesses whether the means of


two groups are statistically different from
each other

Does not consider other factors

When should it be used?

The t-test report in CompAuditor II


gives you a listing of each grouping
regardless of size. This allows you to
quickly see differences in the means.

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Regressions
Regression is a statistical tool used to
understand the relationship between a
dependent variable and one or more
explanatory variables simply a
mathematical model of your pay system
Like prior comparisons, measures
disparities in light of (controlling for)
other factors
Simple Regression one explanatory
variable
Multiple Regression multiple explanatory
variables

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Regression Analysis
Armed with the right tools and the right
data
now we can develop the regression model
In order to develop a regression
model, we need to determine three
things:
Dependent variable
Grouping
Factors that influence the dependent
variable within the grouping

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Regression Analysis
Dependent variable
This refers to the data we are
trying to explain
Base pay
Total cash
Starting pay
Whether or not someone received
a bonus

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Regression Analysis
Grouping
Balance similarly situated
with group size
Typical groupings include:
Job title
Grade
AAP job group

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Regression Analysis
Pay factors
Virtually anything can be coded as a
factor
Some best practice companies check each
factor independently to determine its
influence in the absence of other factors

Typical factors include:


Time factors (seniority, time in job,
experience, etc.)
Market factors
Education factors to the extent they are
different within the selected grouping
2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Percentage of the variation in salaries that is


statistically explained by the independent variables
in the regression model, adjusted for the number of
variables and sample sizes.

Both measure the significance of each variable.


Look for t-stats > |1.96| and p-values < .05 to be
significant. Consider dropping variables that dont
contribute to the model

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Analyzing Compensation
Practices

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

What Compensation
Should Be Analyzed?

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

What Compensation
Should Be Analyzed?
Base salary
Historically what companies have
focused on, both proactively and
for OFCCP audits

Total compensation

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

What Compensation
Should Be Analyzed?
Base salary is only one of the many
elements of total compensation
Base salary
Short-term incentives
Cash bonuses
Annual bonus
Sign-on bonus
Referral bonus
Retention bonus
Holiday bonus
Other cash

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

What Compensation
Should Be Analyzed?
Long-term incentives
Stock options

Employee benefits
Perquisites (perks)
Varies from company to company
Individual packages product of
negotiations
Internal perks
Luxury offices
Executive dining rooms
Special parking and cars
2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

What Compensation
Should Be Analyzed?
Merit Increases
OFCCP is routinely requesting
Do you give $$s or percents?
How does this tie into
performance evaluations?

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Analyzing
Compensation Beyond
Base Pay and
Performance
2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Why Monitor Beyond


Base Pay?
The OFCCP is going to ask for it
Its where the real money lies
Its discretionary
Its an in-house function
generally not outsourced
Its better to do so proactively
today rather than defensively
tomorrow

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Evaluating Compensation
Beyond Base Pay
Analyzing beyond base pay is
not always as simple as a
regression model. Many
factors to consider.
Is a regression model the best test?
Are the groupings you use for base
salary analysis appropriate for this
comparison?
What employees are eligible?

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Evaluating Compensation
Beyond Base Pay
Two phase process
Participation
Impact ratio analysis
Distribution and patterns

Extent of Participation
Regressions
Mean analysis
Distribution and patterns

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Considerations in
Making Pay
Adjustments

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Key Questions
Three key questions
Who should receive a pay adjustment?
How much of an adjustment should be
made?
When should the adjustments be made?

All are strategic decisions with


legal implications

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Who Should Receive Pay


Adjustments
Individuals whose compensation is so low that they
skew the data and no legitimate explanations are
identified should be considered for adjustment
Consult with (as appropriate):
Human resources and compensation staff
Individuals line management
General counsel (risk/benefit analysis)
Senior management

Full story rarely resides in the database or employee


files
Should disadvantaged males and non-minorities be
afforded adjustments

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

How Much of an Adjustment


Should Be Made
Immediate elimination of entire disparity
Amount sufficient to reach bottom of
range
Amount sufficient to eliminate statistical
significance
Additional considerations:
Budget limitations
Will adjustments create new disparities for
men/non-minorities

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

When Should Adjustments


Be Made
During next scheduled compensation
review cycle
Least likely to generate questions

Immediately, mid-cycle
What explanation do you provide employee

Prior to submitting compensation data to


OFCCP or EEOC for analysis
Conduct risk/benefit analysis
What if OFCCP asks

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Conclusion
Prudent employers will conduct
compensation analyses routinely as
part of a proactive, ongoing
monitoring process, and will make
appropriate pay adjustments
regardless of the race or gender of
the individuals affected

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

Wrap-Up and Questions


jnorris@eeac.org
cgokturk@easiconsultants.com

2012 Equal Employment Advisory Council

2012 ILG National Conference | August 28, 2012 |

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