District of Columbia: New Pay Transparency Requirements
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APPLIES TO All Employers with Employees in the District of Columbia |
EFFECTIVE June 30, 2024 |
QUESTIONS? Contact HR On-Call |
Quick Look
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Discussion
On January 12, 2024, the District of Columbia’s mayor signed D.C Act 25-367, amending the Wage Transparency Act of 2014 and requiring employers to provide the minimum and maximum projected salary or hourly pay in all job listings and position descriptions advertised. If the Act is not disapproved during a 30-day congressional review, it will go into effect on June 30, 2024.
In providing the minimum and maximum salary or hourly pay for the position, the range must extend from the lowest to the highest salary or hourly pay that the employer in good faith believes at the time of the posting it would pay for the advertised job, promotion, or transfer opportunity. Additionally, the Act requires that employers include information on the healthcare benefits offered to employees before the first interview. The Act does not define “first interview,” nor does it specify whether a general description of the benefits is sufficient or if more detailed information may be required. There is no requirement, however, to include the healthcare benefit information in the job posting for the open position.
In addition to pay transparency requirements, the Act limits an employer’s ability to seek or use a prospective employee’s wage history by prohibiting employers from screening prospective employees based on their “wage history,” or seeking the wage history of a prospective employee from a person who previously employed the individual. The term “wage history” is defined as “information related to compensation an employee has received from other or previous employment.”
Covered employers will be required to post a notice in a conspicuous place in the workplace notifying employees of their rights under the Wage Transparency Act. The notice must be posted in at least one location where employees congregate.
Action Items
- Update job descriptions for current accuracy.
- Have an equal pay audit conducted and make corrections, as appropriate.
- Identify pay rages based on applicable job descriptions.
- Review job posting templates to prepare for compliance.
- Have appropriate personnel trained on pay transparency requirements.
- Prepare to display required notice when available.
Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2024 ManagEase