We received our first notice under the new Pay Equity Commission enforcement practices introduced in January this year from a client last week.  In the body of the letter they begin by stating: "Commencing in January 2009, the Office will be monitoring employers in your area to ensure that their compensation practices provide for pay equity."

In the past, an Officer would select a company and send a letter saying they were coming in to inspect a client's Pay Equity Status.  Under the new regime they are sending around a questionnaire to determine if the company is in compliance, and whether the company had fully implemented all the changes over the years, and some basic questions on the company's Pay Equity practices.  The big job is to gather all the current and historical information for your company since the Act was implemented and submit this along with the questionnaire.

If the Officer sees no issues from the questionnaire and the supporting documentation they MAY forego an on-site inspection.

The new regime also requires that a Notice regarding Pay Equity be posted for all employees to see and that the employer signs a statement stipulating that this has been done.

If your business answers 'No' to any of the following questions your company is probably not in compliance:

1. Have Up-to-date job descriptions for all full-time, part-time, contract employees, and/or unionized employees.
2. Can identify male, female, and Neutral job classes as defined by the Act.
3. Uses a gender-neutral job evaluation system.
4. Uses a point-factor method for determining the value of the job to the company.
5. Can supply a copy of all salary/wage grids or structures from the point at which your company was required to comply with the Act up to the present.
6. Can supply records showing all retroactive Pay Equity adjustments since the plan's inception.

It's not enough to 'believe' you're in compliance - you have to be able to prove it to the satisfaction of a Pay Equity Officer.

If you receive one these notices, or you think you've fallen behind on maintaining your Pay Equity compliance, or your company never went through the compliance exercise --  it's time to dust off the files and conduct a review.  It's much harder, more disruptive, and more expensive to get the work done in a short time period usually allowed by an Officer.  A stitch in time...

FYI that Simon & Associates does Pay Equity reviews -- the whole job or just vetting your results as you prefer.

If you have any comments or questions please post them below or feel free to contact me for more information.