The IRA—OFCCP Fishbowl Math Debunked

Content Summary

Federal contractors with 100 or more employees must analyze their total selection process for each job or group of jobs, for adverse impact. See, 42 CFR 60-2-17(b)(2). For that purpose, Office of Federal Contract Compliance Programs (OFCCP) use a tool called the Impact Ratio Analysis (IRA). Additionally, OFCCP uses the IRA to extort money from contractors that purportedly discriminate based on gender, race and/or ethnicity. Here we explain how they do this.

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