OPM Directs Agencies to Advance Pay Equity for Federal Employees

OPM is directing agencies to conduct independent pay gap analyses to advance pay equity throughout the federal workforce.

The Office of Personnel Management (OPM) is directing agencies to review their pay policies to advance pay equity among federal employees.

In a memo from Acting Director Robert H. Shriver, III, OPM said that based on its research, female federal employees are paid a little more than 94 cents of every dollar men make, which amounts to an approximately 5.6% gender pay gap. However, OPM said this is an improvement given that it was 25% back in 1992.

The memo lays out instructions for agencies to research and address pay equity among their employees in accordance with President Biden’s two Executive Orders, 14035 and 14069. It also builds on the final rule OPM issued earlier this year in which it banned the use of salary history in setting pay for employment offers to federal employees.

OPM also has conducted a pay gap analysis governmentwide, however, it recommends in the memo that agencies conduct their own to do the following:

  1. Identify areas where any potential gender-related and racial pay disparities exist at agencies
  2. Determine if there are identifiable reasons for any disparities
  3. Provide a basis for the development of targeted strategies to reduce any gender and/or racial pay disparities
  4. Track to see whether strategies to advance diversity, equity and inclusion reduce any such pay disparities over time

OPM recommended that agencies develop a plan to conduct these data analyses on a regular basis.

OPM’s Governmentwide Pay Gap Analysis

When OPM conducted its own pay gap analysis on the federal workforce, it was limited to the following:

  • Executive branch federal employees
  • Federal employees in pay status
  • Federal employees with a “permanent” appointment (i.e., appointment without time
    limitation)
  • Employees with a non-seasonal, full-time work schedule

These were the factors included in the OPM data analysis:

  • Age
  • Gender
  • Grade level (for GS employees)
  • Occupation
  • Pay plan
  • Race/ethnicity

OPM used men’s salaries as the baseline when comparing pay between men and women. Average female salary was expressed as a percentage of the average male salary. For example, in 2022, OPM found that the average female salary was 94.4% of the average male salary for the Executive branch workforce.

When studying race/ethnicity, OPM used white male salaries as the baseline for comparison. Average male and female salaries were expressed as a percentage of the average white male salary. In 2022 for instance, OPM found that the average black female salary was 85.1% of the average white male salary for the Executive branch workforce.

Pay Gap Analysis Supporting Documents

OPM provided two separate documents with the pay equity memo:

  1. Independent Pay System Review and Certification
  2. Agency Pay Gap Data Analysis Guidance

These are provided to assist agencies in conducting their own pay gap analyses. OPM recommends that agencies conduct an analysis similar to OPM’s governmentwide analysis and use data for the most recent fiscal year.

OPM recommends that agencies conduct a targeted analysis of:

  • Governmentwide pay systems (for example, General Schedule) and large independent pay systems administered by the agency (covering 100 or more employees in a given population);
  • Major occupations; and
  • Subpopulations with the largest gender-based and racial/ethnic-based pay
    disparities.

Agency HR offices and staff can contact OPM at paypolicy@opm.gov for additional information on conducting the independent pay system analysis or pay gap data analysis.

About the Author

Ian Smith is one of the co-founders of FedSmith.com. He has over 20 years of combined experience in media and government services, having worked at two government contracting firms and an online news and web development company prior to his current role at FedSmith.