Q&A
Discussion of Intro 808 and its potential impact on wage transparency
1:06:33
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141 sec
JoAnn Kamuf Ward discusses Intro 808, which aims to expand wage transparency requirements, and its potential impact on addressing wage disparities in New York City.
- CCHR supports the aims of Intro 808 and sees potential positives in articulating a range of relevant factors for wage determination
- There are concerns about how an enumerated list might be interpreted by employers and lawyers
- The bill's approach differs from percentage-based or numerical band approaches used in other jurisdictions
- Record-keeping provisions may be burdensome for smaller employers but helpful for investigations and future job applicants
- There are concerns about the breadth of non-wage compensation information required and how to make it accessible to job applicants
JoAnn Kamuf Ward
1:06:33
about yeah.
1:06:34
So I will speak I I will speak on 808.
1:06:36
Hey.
1:06:38
So, I think, you know, we we have already stated that we support, support the aims.
1:06:45
I think we see potential positives to having a range of relevant factors articulated.
1:06:53
I think one thing that we have flagged just from an enforcement perspective is as soon as you have an enumerated list, employers or other covered entities will say, that's the only thing I need to consider.
1:07:06
Or you didn't say this was relevant, so maybe that's not relevant.
1:07:10
That's how lawyers tend to operate.
1:07:12
But, but I think we have seen other approaches in other jurisdictions that are percentages or some other kind of numerical band, which I think to CCHR does not, reflect the reality of the size of businesses that we interact with.
1:07:28
Right?
1:07:28
There's gonna be different expectations, I think, for much smaller businesses than much larger businesses.
1:07:33
So I think the factors will help in the future of the implementation of this law, identify, you know, what what are employers looking at.
1:07:43
It also gives more guidance to employers who, I think, often felt they were not sure what their what their range should should include.
1:07:52
Similarly, I think the record keeping provision, it's likely going to be a burden on smaller employers.
1:07:58
Again, I'm thinking of the the the very small employers covered by our law.
1:08:03
But I think from an investigatory perspective, having a record of why something deviated from the posting, will be helpful, for for our work, but also for for future job applicants.
1:08:16
I think the the one flag that we had was just, for the the inclusion of non wage compensation, the breadth of what that can entail, and balancing the job posting, which is increasingly, like, 4 words on Twitter or LinkedIn, and just thinking about ways that you can make that information accessible to employees or job applicants in a sort of accessible way, easy to find, not hidden somewhere, but maybe not all in the job posting.
1:08:49
That's a that's something we'd wanna hear from advocates about because that's just a kind of anecdotal reaction.