Pay Equity Study Update: FAQ
This FAQ is a living document that is updated as new information becomes available. It was first posted on January 21, 2020.
Q: Why is pay equity important at the University of Denver?
A: Equitable pay for our employees is critical to creating an equitable environment for all who live, work and study here. Our wholehearted support for pay equity takes on even greater importance as we navigate both the impacts of Covid-19 and our growing awareness that many people on our campus experience inequity and marginalization. More than ever, we now must closely examine all of our policies and decisions in the context of race, gender, and other aspects of our complex identities.
Q: What is a pay equity study, and why is DU doing one?
A: Pay equity studies are designed to determine whether there are systemic inequities impacting the salaries of employees on the basis of sex, race/ethnicity, or age. As announced to the DU community in July 2019, DU appointed a Pay Equity Advisory Committee, which provided advice and guidance that resulted in the hiring of an independent consultant, Gallagher Human Resources and Compensation Consulting, to examine the salary data for all of our non-union, benefited faculty and staff. The study, which follows the significant market-based salary corrections we have made in the past for both faculty and staff, and is part of our continuing efforts to make DU an equitable, diverse, and welcoming community as expressed through our systems and our culture.
Q: What is the current status of the pay equity study? And what will happen next?
A: Gallagher has examined fiscal year 2018–19 data salary data provided by DU, and has presented initial findings to the Advisory Committee. While the committee is confident in Gallagher’s initial findings, a subcommittee of the Pay Equity Committee, comprised of faculty and staff with expertise in statistics and research methodology will be taking a closer at Gallagher’s results, and offering advice on such aspects of the project as approach, results, and communication to the campus community. DU also has engaged Gallagher to evaluate and provide recommendations for staff job architecture, job levels, and career pathing within the University. A dedicated advisory group is currently being formed to ensure that we have strategic partnership and collaboration for this second phase of the project, which we expect to complete by the end of the calendar year.
Q: Has Gallagher recommended any changes to our overall policies?
A: Yes, they recommended two adjustments in the interest of ensuring greater equity: (a) that we standardize performance-management guidelines for faculty and staff; and (b) that we update our guidelines regarding temporary salary increases. More information about staff salary grades and compensation can be found here. A message to the community dated August 19 contains more information about the recommendations.
Q: When and why did the pay equity study start?
A: Chancellor Rebecca Chopp (now Chancellor Emeritus) initiated the University-wide Pay Equity Study to promote equity and fairness in how DU treats all employees. Chancellor Jeremy Haefner championed the study when he served as provost and executive vice chancellor, and now, as Chancellor, he has continued his commitment to addressing any inequities that the study reveals.
Q: What does “pay equity” mean?
A: Pay equity is also known as “equal pay for equal work.” Signed by President John F. Kennedy, the Equal Pay Act (EPA) of 1963 requires that men and women receive equal pay for equal work in the same establishment. The jobs do not need to be identical, but they must be substantially equal. It is job content, rather than job titles, that determines whether jobs are substantially equal. Specifically, the EPA provides that employers may not pay unequal wages to men and women who perform jobs that require substantially equal skill, effort and responsibility, and that are performed under similar working conditions within the same establishment (EEOC, 2019).
Q: What is the law in Colorado?
A: In April 2019, the Colorado legislature passed Senate Bill 85, called the Equal Pay for Equal Work Act. Similar to federal law, this state law prohibits employers from paying different wages based on sex. The law also requires employers to announce new job opportunities and include salary ranges in all job postings. And it creates a process to administer and mediate pay equity complaints. Once the new law goes into effect—on January 1, 2021—employers can be held financially accountable if the sex-based pay discrimination is found to be intentional.
Q: Is this why the University is conducting a pay equity study?
A: No. Commitment to equity is one of DU’s fundamental values. As an Affirmative Action employer, we already review and report on our salary practices and data on an annual basis. When we began the study, we were reasonably confident that most salaries were in line with our goal to have a fair and equitable approach towards compensation. Nevertheless, we chose to conduct this pay equity study using an external consultant to examine our data and processes in a more granular and specific fashion. We have leadership support for our many University-wide diversity and inclusion initiatives. We hope every member of this community will understand and appreciate our commitment and support for equitable pay as a critical value.
Q: Is the University required to do this study? Is it related to the accusations of pay inequities in DU’s Sturm College of Law?
A: No, the study is voluntary. It also is completely separate from the equity initiatives that apply specifically to the law school.
Q: How does this pay equity study relate to the compensation studies done in the recent past?
A: The pay equity study is one of an ongoing series of projects designed to address compensation at DU. As an Affirmative Action employer, the University reviews faculty and staff salary practices and data on an annual basis to determine whether there are sex, race, or ethnicity-based disparities. In 2015, the University established staff salary grades and pay levels. Through a $2.1 million investment, the University provided salary adjustments to 423 staff members and brought 100 percent of benefited staff to at least 85 percent of their salary-grade midpoint. In 2018, the University adjusted a smaller number of staff salaries based on years of service, performance rating, and compensation ratio (relative to market rate). Now, the 2020 pay equity study will analyze internal faculty and staff salary data to identify and correct potential pay inequities based on sex, age or race/ethnicity. The study also will review internal pay practices to identify any systemic issues that might unintentionally perpetuate inequity in the future. It is important, however, to understand the difference between market adjustments previously given and the pay equity study. Please see below for further clarification.
Q: Who is making sure the study is fair and accurately done?
A: While serving as provost and executive vice chancellor, Chancellor Haefner appointed a pay equity advisory committee, which he charged with determining “whether there are systemic inequities affecting our non-union benefitted faculty and staff salaries based on sex and underrepresented minority status.” He asked the committee to oversee the administration of a pay equity study, specifically to offer advice on vendor selection, study approach, and communication to the campus community. In July 2019, after a thorough RFP process, the committee chose Gallagher Human Resources and Compensation Consulting as the vendor to conduct the study. Gallagher has a global reputation for their work in higher education and for their commitment to diversity and inclusivity. In October 2019, with the committee’s oversight, DU provided data to Gallagher to begin the review.
Q: Who serves on the Pay Equity Advisory Committee, and how were the members chosen?
A: The committee is comprised of nine faculty members, seven staff members, two deans, and a representative from the Office of Diversity and Inclusion. Members were either nominated by faculty and staff or they expressed interest in participating. Their names were announced in July 2019 and can be found here.
Q: Will anyone’s pay be reduced as a result of the study?
A: Definitely not. The Equal Employment Opportunity Commission (EEOC) has stated that, if there is a disparity in wages between men and women, employers may not reduce the wages of either men or women to comply with the Equal Pay Act. In addition, DU is committed to promoting equity based not only on sex, but also on age, race and ethnicity.
Q: After the study, how will DU ensure equitable pay in the future?
A: In addition to reviewing our current data, Gallagher reviewed all of the University’s pay practices. We will follow their recommendations to ensure that the University has systems in place to promote fair and equitable pay in the future. Also, as an Affirmative Action employer, we will continue to review faculty and staff salary practices and data on an annual basis.
Q: How does the study compare faculty roles in different disciplines?
A: The data provided to Gallagher uses a salary factor to distinguish the market rate for different disciplines, similar to compensation grades for staff. The salary factor is the ratio of the average salary for a given academic rank and specific discipline to the overall average salary across all disciplines for that rank.
Q: Whom can I reach out to with questions?
A: Email HR.Compensation@du.edu
The following graphic explains what the pay equity study is and is not.
Pay Equity Glossary
We offer the following definitions to facilitate an accurate understanding of the communications materials related to the University of Denver’s 2020 pay equity study.
Affirmative Action employer
An employer who proactively recruits, hires and promotes minorities, women, disabled individuals and veterans with the intent of increasing the representation of underrepresented groups.
Colorado Equal Pay for Equal Work Act (Senate Bill 85)
This legislation prohibits Colorado employers from discriminating on the basis of sex by paying different wages to employees of different sexes for substantially similar work using a composite of skill, effort and responsibility.
Wages paid by an organization to employees in exchange for work, including bonuses.
An employee’s comparison ratio (compa-ratio) is calculated by taking their annual salary and dividing it by the midpoint of their salary grade. The closer someone is to the midpoint (compa-ratio = 1), the more competitive to the market their salary is.
Compensation and benefits comparable to other employers in the same industry and geographical area.
Federal Equal Pay for Equal Work Act (EPA of 1963)
The Equal Pay for Equal Work Act prohibits employers from paying women less than men for doing the same or substantially the same work at the same facility.
Equal pay for equal work
Compares the pay of two specific employees, one male and one female, doing the same or substantially similar work.
Internal consistency of salary amongst employees within an organization.
External market data
An organization’s relative position in the marketplace when compared to other companies in the same industry.
Pay at a level that matches the market average salary for a specific job.
Paying employees fairly and consistently, without discrimination, but taking into account job-related factors such as performance, education, work experience, and tenure.
Pay equity study
An analysis to determine whether there are systemic inequities affecting employees at an organization based on gender and underrepresented minority status.
Protected and non-protected groups
Under federal law, employers cannot discriminate against protected groups on the basis of race, color, national origin, religion, sex, age, or disability. However, not every group is a protected class under federal law. If a person is not a member of one of the designated groups, they may not be protected under federal or state anti-discrimination laws. Examples include people with criminal records, undocumented aliens, or individuals with varying education levels.
When the pay of employees in lower-level jobs are paid almost as much as their colleagues in higher-level jobs.
The salary factor is the ratio of the average salary for a given academic rank and specific discipline to the overall average salary across all disciplines for that rank.
A salary grade is a step within a salary structure that helps define the amount of pay an employee will receive. Ranges are defined by relevant market data and are based internally on roles, responsibilities, qualifications, and competencies, as well as the skills and experience of the incumbent as they relate to the organizational structure.
Salary grade mid-point
The middle point of a salary range’s minimum and maximum.