The Ontario Pay Equity Act is a pro-active pay equity scheme that to date has been administered by a separate and specialist Pay Equity Commission and Pay Equity Hearings Tribunal.
The Ontario Act applies to
- all employers in the public sector;
- all employers in the broader public sector; and
- all employers in the private sector with more than 10 employees.
Under the Act, all of these employers have a pro-active obligation to examine their workplaces and to achieve pay equity after determining the value of work based on a composite of skill, effort, responsibility and working conditions: s. 7, s. 5.
The Act requires all public sector employers and all private sector employers with more than one hundred employees to post a pay equity plan: s. 13. Private sector employers with less than one hundred employees can choose whether to post a plan: s.19. If they posted a plan they could take advantage of provisions which allowed them to phase in pay equity. If they didn't post a plan, they had to fully achieve pay equity within six years: s. 20, s. 21.
The Act contemplates that an employer may need to prepare several pay equity plans for an establishment. The Act mandates a separate plan for each bargaining unit as well as a separate plan for non-unionized employees: s. 14.
Where employees are unionized, the Act imposes an obligation on the employer to negotiate with the union in good faith and to endeavour to achieve a pay equity plan. The negotiations cover all aspects of the pay equity plan, from the selection of the gender neutral comparison method through to the implementation of the plan: s. 14. The employer must also negotiate in good faith with the union if the pay equity plan is to be amended in light of changed circumstances at the workplace: s. 14.1.
Where employees are not unionized, the Act requires that the employer prepare the pay equity plan, give the employees 90 days to review and comment on the plan, and the employer can amend the plan in light of those comments. After the employer posts the pay equity plan, the employees have 30 days to file a notice of objection with the Commission if they believe there are problems with the plan: s. 15. Again, where there are changed circumstances, the employer must allow the employees to review and comment on the plan and the employees again have an opportunity to file an objection with the Commission: s. 14.2.
The legislation prescribes the comparison methods that the parties must use in achieving pay equity and prescribes the order in which these methods must be applied.
- First, the parties must attempt to use the job-to-job comparison method. With the job-to-job comparison method, one tries to match a specific female job to a specific male job of equal or similar value. In searching for comparators, one looks first within the bargaining unit and if there is no comparator, one then looks to non-bargaining unit jobs: Part II and Part III.
- If there are female jobs that have not been matched using the job-to-job method, the parties then proceed to use the proportional value comparison method. This is basically a wage line method. Either by plotting on a graph or using regression analysis, a wage line is drawn for male jobs. Female jobs whose pay fall below the male wage line are given adjustments to bring them up to the male wage line: Part III.1.
- In the broader public sector only, if there are female job classes that have not achieved pay equity using either the job-to-job method or the proportional value method, one can then use the proxy comparison method. Generally speaking, broader public sector workplaces are almost exclusively female, ie. no male job classes. Under the proxy comparison method, the employer trying to achieve pay equity – the seeking employer – refers to a comparable female job class in a designated proxy institution – the proxy employer – which has already achieved pay equity. The wages of the female job classes at the seeking employer are raised to the level of the female job classes at the proxy employer. The legislation prescribes which institutions are the proxy employers for which broader public sector organizations: Part III.2.
Ontario's Pay Equity Act came into effect in mid-1987 and it established deadlines by which different kinds of employers were obliged to post pay equity plans. Depending on the size of the employer, employers had between 2 and 5 years to post a pay equity plan: s. 10.
Public sector employers had to post by
Private sector employers had a sliding deadline based on size |
1990 |
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500+ employees
100+ employees
50+ employees
<50 employees |
1990
1991
1992
1993 |
When the Act was initially introduced, it only included the job-to-job comparison method. Proportional value and proxy comparisons were introduced in mid-1993. Proportional value plans and proxy plans were to be posted by 1994: s. 21.7; s. 21.19.
The Act also prescribes that employers are required, at a minimum, to devote an amount equal to 1% of payroll per year towards paying out pay equity adjustments: s.13(4). It also prescribes when those payments had to commence: s. 13(2); s. 21.10; s. 21.22.
For public sector employers, payments had to commence 1 January 1990 and all pay equity adjustments had to be fully paid out by 1 January 1998: s. 13(7).
For private sector employers, again the payment schedule was based on size and the comparison method used:
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500+ employees
100+ employees
50+ employees
<50 employees
proportional value (50+ employees)
proportional value (<50 employees)
proxy |
1991
1992
1993
1994
1993
1994
1994 |
Only the public sector had a deadline for when all pay equity adjustments had to be fully paid out. All other employers are allowed to devote 1% of payroll per year towards adjustments until such time as the adjustments are fully paid out.
The Ontario Act is enforced by the Pay Equity Commission which consists of the Pay Equity Office and the Pay Equity Hearings Tribunal.
Broadly speaking, the Pay Equity Office has two different functions. One is to conduct research and public education on pay equity and provide support services to the Hearings Tribunal. The other is to act as the first level of enforcement of the Act.
A number of the Pay Equity Office employees are designated as Review Officers. When a party (be it employer, union or individual employee) complains about a pay equity plan, the first step of enforcement is that the complaint is referred to a Review Officer. The Review Officer has the mandate to monitor the preparation and implementation of pay equity plans, to investigate objections and complaints filed with the Commission, to attempt to effect settlement, and if settlement is not possible, to make orders deciding any outstanding issues: s. 34; s. 23; s. 24.
A matter can only go the Hearings Tribunal after it has been subject to investigation by the Review Officer: s. 25.
First, a review officer can decline to deal with a complaint because it is trivial, frivolous, vexatious or not within the jurisdiction of the Commission. The review officer will notify the complainant, and the complaint may request a hearing before the Hearings Tribunal in relation to the decision: s. 23(4).
Second, if a review officer makes an order and an employer or bargaining agent fails to comply with the order, the review officer can refer the matter to the Hearings Tribunal: s. 24(5).
Third, if a review officer makes an order, an employer, bargaining agent or individual complainant may request a hearing before the Tribunal: s. 24(6).
Fourth, if a review officer investigates, fails to effect settlement but does not make an order, then the parties may request a hearing: s. 25(1)(a).
Hearings before the Tribunal are conducted before a 3-person panel consisting of a presiding officer, an employer representative and an employee representative: s. 29. |
The three major strengths of the Ontario Pay Equity Act are
- that the law is pro-active;
- that unions play a full role in negotiating and enforcing pay equity plans; and
- that the law has been enforced by a separate independent specialized commission.
A. A Pro-Active Pay Equity Act
First, the fact that the Ontario legislation is pro-active allows for more comprehensive coverage than is possible under a complaints-based model. It ensures broader access to pay equity. Enforcement can happen more globally rather than on a piecemeal workplace by workplace basis which depends on having individuals sufficiently brave and persistent to file a complaint.
Second, pro-active legislation has been instrumental in enabling unions to get employers to the table. Pro-active legislation cuts down on the culture of resistance. Employers know they have to go through the process so while they may not be keen to do it, they know ultimately they have to comply.
Pro-active legislation also acts to level the playing field somewhat. An employer will not want to do something that increases wages if they feel that their competitors will not do it. A pro-active Act ensures that all employers are subject to the same requirements and no one gains a competitive advantage by dodging a complaint.
Having a pro-active Act is particularly important for non-unionized women who often don't have any information about what other workers are being paid and who have less chance of achieving pay equity in a complaint-based system. While non-unionized women are the women who have benefited least from the Act, having a pro-active Act is a better starting point for them than having a complaint-based system.
B. Unions' Role in Negotiating and Implementing Pay Equity
Giving unions a direct role in the negotiation and enforcement of the Pay Equity Act is I believe one of the keys that has made this legislation successful.
Unions have been actively engaged in the entire process of developing pay equity plans. They have been involved in
- negotiating what is an appropriate gender neutral comparison method;
- identifying what are male and female job classes;
- educating their members about what pay equity means and in how to complete pay equity job questionnaires;
- negotiating what value should be assigned to different jobs;
- negotiating appropriate comparators and comparison methods;
- negotiating what pay adjustments are required;
- following up to ensure that pay equity adjustments are paid out;
- negotiating with respect to amendments to plans in light of changed circumstances and following up to enforce maintenance of pay equity.
The fact that unions are given a direct role in negotiating and that the employer is bound by a duty to bargain in good faith gives the union real influence in shaping the pay equity plan and protecting the interests of its members.
Because the union has this direct involvement, the union has direct authority to file a complaint with the Commission, to call on the services of a review officer, or to request a hearing before the Tribunal.
This I think can be contrasted favourably with the federal Employment Equity Act under which unions are given no direct role in terms of either negotiating employment equity plans or seeking to enforce them.
One other factor that is significant about the pay equity negotiations is that they are conducted separately from regular collective bargaining. This is good because pay equity does not then become subject to the kinds of trade offs and give and take in regular collective bargaining. Pay equity, as anti-discrimination law, is a matter of fundamental human rights that should not be subject to trade offs in bargaining. Also, by keeping pay equity separate, women's interests are not pitted against men's interests in bargaining which reduces internal union conflict.
C. An Independent and Specialized Pay Equity Commission
It has been tremendously useful to have a specialized Pay Equity Commission charged with enforcing the Act. Pay equity is a specialized area of employment/labour law and a specialized area of human rights law. As a result it requires a special expertise.
The Pay Equity Office in its research and education role has developed a high level
of expertise and as a result, has developed a number of very useful guides and precedents that are very helpful in negotiating pay equity plans. For example, they have also developed a number of precedent gender neutral job comparison systems that are tailored to different kinds of workplaces, i.e. small workplaces, larger private sectors workplaces, broader public sector workplaces. These involve gender neutral questionnaires for collecting information about job classes and guides on how to evaluate jobs in a gender neutral way. They have also developed lists of women's skills that are generally overlooked in evaluating jobs, which are very useful in helping employees to fill out questionnaires that recognize what they do.
Having a specialized Commission also means that review officers and tribunal adjudicators have a high level of expertise in the area and are able to develop a consistent and high quality jurisprudence.
I note, however, that speak at the end of February 2001, the Ontario government announced its plan to consolidate a number of employment-related administrative tribunals into a "Super Tribunal".
Their proposal is to amalgamate the Ontario Labour Relations Board, Ontario Workplace Safety and Insurance Appeals Tribunal, Pay Equity Hearings Tribunal, Human Rights Board of Inquiry, the Education Relations Commission and the College Relations Commission into a single Super Tribunal.
The government also proposes to have all or some of the functions of the Pay Equity Office delivered by the Ministry of Labour.
D. No Reprisals Provisions
A fourth strong point of the Act that should be mentioned is the "no reprisals" provision found in section 9 of the statute.
First s. 9(1) provides that no employee's compensation will be reduced in order to achieve pay equity.
Second, s. 9(2) provides that no employer, employee or bargaining agent shall intimidate, coerce, penalize or discriminate against a person because they have participated in a proceeding under the Act, have made a disclosure required by the Act, have exercised any right under the Act, or have acted in compliance with the Act.
Where a reprisal has taken the form of a dismissal, the Tribunal has the authority to order reinstatement. Where as a result of the reprisal the employee has lost money or had their pay level decreased, the Tribunal also has the authority to restore the employee's compensation and to order the employer to pay all lost compensation: s. 25(2)(a)(b).
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I turn now to consider the ways in which new federal pay equity legislation could improve upon the Ontario Act. The key areas I'll focus on are
- first, some specific suggestions with respect to the provisions dealing with preparation of pay equity plans; and
- second, some broader suggestions regarding the enforcement mechanisms under the Act. These include:
- ways to increase compliance;
- ways to improve access to enforcement;
- ways to strengthen enforcement; and
- ways to ensure that women get the money that is owed to them.
A. "Technical" Suggestions for Building a Stronger Act
The four areas I want to look at in terms of specific "technical" suggestions are
- application of the Act;
- disclosure;
- legislative direction on how to conduct job comparisons; and
- maintenance of pay equity.
1. Application of the Act
First, application of the Act. As I explained, the Act is pro-active and it sets deadlines by which pay equity plans are to be posted by different size employers. One problem we have run into is new employers, that have come into existence or entered Ontario after the deadlines, saying that pay equity is finished and that it does not apply to them. They have made this argument on the basis of some vague language in the Act. There are good things in the Ontario Act, but its structure is awkward and confusing.
- Part I of the Act sets out some general principles of the Act, including the pro-active obligation to establish and maintain pay equity. Section 3 of the Act expressly states that
"3. (1) This Act applies to all employers in the private sector in Ontario who employ ten or more employees, all employers in the public sector, the employees of employers to whom this Act applies and to their bargaining agents, if any.
(2) If at any time after the coming into force of this Act an employer employs ten or more employees in Ontario, this Act applies with respect to the employer although the number of employees is subsequently reduced to fewer than ten."
Section 7(1) expressly states that "Every employer shall establish and maintain compensation practices that provide for pay equity in every establishment of the employer."
- Part II of the Act relates to the implementation of pay equity for public sector and larger private sector employers. Part II applies "to all employers in the public sector, all employers in the private sector who, on the effective date, employ 100 or more employees and those employers in the private sector who post a notice under section 20". In addition, some sections apply "to public sector employers that did not have employees on the effective date but that had employees on July 1, 1993."
- Part III of the Act applies to small private sector employers. It gave the option to post a plan. Part III was repealed 1 January 1994.
Part III.1 of the Act deals with proportional value plans. This Part "applies to employers to whom Part II applies and to public sector employers that did not have employees on the effective date but that had employees on July 1, 1993."
Arguments are being raised by employers who came into existence after 1 July 1993 that the Act doesn't apply to them. Our position is that these employers are bound by the Act but that they cannot take advantage of the earlier timetables for phasing in pay equity gradually. This confusion could be avoided by drafting federal legislation with a cleaner structure. It could also be avoided by including very straightforward language stating that employers that come into existence after the coming into force of the federal pay equity act are required to comply with the act immediately, and that the requirements to post a plan, negotiate in good faith, etc. apply to them.
2. Disclosure
What kind of disclosure employers must make in the course of pay equity negotiations was an issue that spawned a fair bit of litigation early in the history of Ontario's Pay Equity Act because employers refused to disclose the full extent of information that was necessary for unions to be able to properly negotiate a plan. A Tribunal ruling eventually set out the nature and extent of disclosure that was required.
In order to negotiate with respect to pay equity in good faith, unions need access to a lot of documents and information about the workplace that were not necessarily readily available to them. Some of the kinds of documents they need include:
- information about what job evaluations/wage setting practices existed prior to pay equity negotiations;
- job descriptions, job postings and/or employment manuals relating to the job classes both inside and outside the bargaining unit;
- current wage rates with respect to the non-union male job classes;
- information with respect to the implementation of the pay equity plan (ie: when were the adjustments paid out; when were the adjustments completed);
- all information relating to efforts to maintain pay equity;
A lot of difficulty and litigation could be pre-empted in the federal sector by including in new federal legislation express provisions setting out the employer's obligation to disclose all documents relevant to the pay equity negotiations and, without in any way limiting that obligation, listing specific kinds of documents that are subject to disclosure. In light of obligations to maintain pay equity, this should be a continuing obligation.
In a similar way, legislation could head off a lot of litigation under a federal act by providing a definition of employer and establishment. Again, what constitutes an employer's "establishment" was also subject to a great deal of litigation early on in Ontario's experience under the Act and has been subject to dispute under the existing federal legislation.
3. Prescribing Job Comparison Methods
A third technical matter is job comparison methods. With respect to conducting comparisons, the Ontario Act creates an odd system. It mandates that parties first use job-to-job. If there are any female jobs left over, they must then use proportional value to provide comparators for these jobs. In the broader public sector, if job-to-job and proportional value don't allow the workplace to achieve pay equity, they must try the proxy comparison method.
This three stage approach reflects how the Act evolved. When the Act was introduced in 1987 it included only the job-to-job comparison method. However, the government recognized that this was not going to be sufficient to allow all female job classes to achieve pay equity. The 1987 legislation mandated the Pay Equity Office to conduct studies of female dominated sectors of the economy to determine what further methods of comparison would be useful to achieving pay equity in these areas. The Pay Equity Office ultimately recommended proportional value and recommended proxy for the broader public sector. These were introduced in 1993 after employers were already supposed to have completed their job-to-job comparisons. Rather than making employers redo their entire plans, the legislation required them simply to find matches for the job classes that were not matched using job-to-job.
I think it is a good thing that the legislation prescribes what comparison methods can appropriately be used to achieve pay equity. However, if the legislation were being designed from scratch, I think it would be better not to prescribe that employers follow this three step analysis of using first job-to-job then proportional then possibly proxy.
Some problems with prescribing this three-step method for comparison are that it is too rigid. An employer may be forced to prepare a number of different plans using different methodologies which increases the time and effort required to achieve pay equity and decreases the willingness to comply. A further concern is that using the job-to-job comparison method has in some circumstances caused internal union tension because women and men in specific jobs felt they were being pitted against each other. Using a number of different comparison methods also complicates the issue of how pay equity should be maintained.
I would recommend that the federal legislation either
- identify the comparison methods that are considered appropriate for achieving pay equity and allow the parties to choose which method fits best with their workplace; or
- simply use the proportional value method.
The advantage of using only the proportional value method is that it provides the most accurate depiction of the male wage line. It does not pit female job and male jobs directly against each other. It also makes maintenance simpler. For example, under the current system, if a male job class is phased out, or is substantially changed, a female job class may lose its comparator. Problems then arise about how or whether it is possible to maintain pay equity for that female job class. If proportional value is used, a female job class is not inextricably linked to a particular male job class. If the male job class goes, then female job class can still be compared to the male wage line.
4. Maintaining Pay Equity
Finally, maintaining pay equity. The Act contains a general obligation to establish and maintain compensation practices that provide for pay equity.
There is real uncertainty about what maintenance requires and there is at this stage little case law to assist parties. Federal legislation could improve on this by spelling out what maintenance means and by requiring that every pay equity plan include a maintenance plan by which the employer and the union agree to review the pay equity plan on a regular basis - say yearly, or every other year - to ensure that pay equity is being maintained.
The Ontario Act includes one specific detail on maintenance, but I think it should be repealed. Section 8(2) provides that after pay equity has been achieved, the Act does not prevent differences in pay from being reintroduced when they arise due to differences in bargaining strength. [Unions did not request this provision when the Ontario legislation was introduced.] It is very hard to prove that the reason that a difference in wages has emerged is due to "bargaining strength". In any event, such an exclusion is inconsistent with the purpose of the Act because it simply allows gender discrimination to be reintroduced.
B. Strengthening Enforcement Mechanisms in a Federal Act
Having looked at some suggestions for improving "technical" aspects of the Act, I turn now to consider some broader suggestions for improving the enforcement of pay equity.
1. Strengthening Compliance
Mechanisms
Even though the Ontario legislation imposes a pro-active obligation to make a pay equity plan and imposes a pro-active obligation to maintain pay equity, this does not by any stretch mean that all employers comply with the Act.
In 1997-1998, 40% of large private sector employers (employers with over 100 employees) had not prepared pay equity plans even though they were required to do this by 1991-1993. For employers with less than fifty employees, only 20% had taken any steps towards compliance with the Act.
Apart from union vigilance, the Ontario Act contains no effective method of monitoring compliance both in respect of initial compliance with the requirement to make a pay equity plan and with respect to continuing obligations to maintain pay equity.
Monitoring and compliance could be improved by including explicit reporting requirements in the Act.
I would recommend that the federal Act impose a pro-active obligation on every federal sector employer to prepare and file a pay equity plan with the pay equity commission. Section 13 of the Ontario Act sets out a number of items that must be included in a pay equity plan. These include:
- identifying the establishment to which the plan applies;
- identifying all the job classes and identifying which are male and female job classes;
- describing the gender neutral comparison system that has been used;
- setting out the results of the job comparisons;
- identifying which job classes are entitled to pay equity adjustments;
- setting out a payment schedule for pay equity adjustments
All this information should be included in the plan and filed with the Commission. In addition, the federal Act should require that pay equity plans include a section setting out employees' rights to complain to the Commission with respect to any problems in the plan.
In addition, employers should be required to file follow up reports on an annual basis indicating what they have done to comply with pay equity requirements, i.e. detailing what pay equity adjustments have been paid out, how much is still owing, whether any amendments have been required to the plans etc.
Employers should be required to post plans in workplace so that non-unionized employees have access to plan. They should also be subject to an ongoing obligation to report to employees/bargaining agents on maintenance and employees/bargaining agents should have an ongoing right to access that information.
To give teeth to the monitoring, it would also be useful to give the Commission authority to initiate investigations into plans which do not appear to provide true pay equity or which do not appear to properly maintain pay equity and to conduct audits.
2. Improving Access to Pay Equity Enforcement
In connection with the issue of compliance, it is important to recognize that non-unionized women have had the most difficulty and least success in accessing pay equity. They lack the resources to be able to monitor compliance and to challenge the employer's comparison or evaluation of jobs.
It is crucial to be able to develop an enforcement system that allows non-unionized women to be able to fully access their rights.
When the Ontario Act was initially introduced, the Ontario government created a special legal clinic – PEALS – the Pay Equity Advocacy and Legal Services which provided consulting and legal services to non-unionized women. PEALS was not created under the Pay Equity Act. There is no mention of it. When the Harris government was elected it ceased funding to PEALS.
New federal legislation should include in the statute itself a commitment to creating and funding some sort of consulting and advocacy body to assist non-unionized women to enforce their rights.
Along with the reporting measures I've suggested above and along with giving the Commission authority to initiate its own investigation into compliance and conduct audits, this should go some ways to assisting non-unionized women.
3. Improving the Administrative Machinery for Enforcement
While investigations by review officers are helpful in moving some pay equity disputes along, one of the practical problems in enforcing the Ontario Act is that it is difficult to get review officers to make orders. Because it is mandatory that a complaint be investigated by a review officer before a matter can proceed to the Tribunal, this slows down enforcement considerably and makes it difficult to get before the Tribunal.
I think that pay equity should continue to be enforced by a separate and specialized administrative tribunal. However, I would recommend some structural changes to how that enforcement works.
Briefly, I would recommend having a Pay Equity Office that is charged with education and research, monitoring and audits, and that has the authority to initiate complaints. I would then recommend that employers, bargaining agents and employees have a right to make applications directly to the Hearings Tribunal. The Hearings Tribunal could include a voluntary mediation service. However, if the parties do not wish to mediate, they should be able to take their complaint directly to a hearing. Third, I would recommend that there be a separate advocacy service, like PEALS, that could provide advice and support to employees and unions trying to enforce their rights.
I would also recommend that the adjudicators on the Tribunal be appointed for relatively long term appointments to ensure institutional independence and to allow for the maximum development of expertise. As a practical matter, one of the problems that we have been running into at the Ontario Tribunal is that chairs are appointed on Order-in-Council for extremely short tenure. Apart from the concerns this raises with respect to institutional independence, this results in real problems. It is difficult to get a hearing date because the Tribunal does not know which adjudicators will be reappointed. I would recommend that adjudicators be appointed for approximately 5-year terms.
4. How do you get the money?
Once parties have negotiated a pay equity plan, one problem we have faced on a recurring basis is how to get the money from the employer. I'm going to address three different contexts in which this has arisen.
First, under the Act I mentioned that there is an obligation for the employer to devote at least 1% of payroll per year towards making pay equity adjustments. On the one hand it is good to include this requirement in the Act. Again, it cuts down on resistance. The employer knows that they must devote this money to pay equity. On the other hand, apart from the public sector, there is no end date for when pay equity must be achieved. In practice this means that it can take many years, even quite literally generations, for a pay equity wage gap to be closed. I would recommend then that the legislation include a minimum that must be devoted each year towards pay equity and an end date by which full pay equity must be achieved.
Second, another problem that we have run into is that even where employers have a clear commitment to pay certain monies in a pay equity plan, they will refuse or delay; it takes years to get before the Tribunal and the employer has deferred payments for this entire period without penalty. The Ontario Tribunal does not have express jurisdiction to award interest and so has never made such an order. Enforcement in the federal sector would be much stronger if new federal legislation expressly granted the Tribunal the authority to make awards of interest. This would deter employers from delaying payments and would fairly compensate employees when employers did delay. In addition, if there is a 1% of payroll per year requirement, it would have to be useful to make clear that any interest payments are in addition to this 1%.
Third, a big problem we are facing in the broader public sector is that the Ontario legislation does not expressly commit the provincial government to funding pay equity in the broader public sector. Broader public sector employers receive virtually all their funding from government and they are highly regulated by government in terms of the nature and level of service they provide. Without additional government funding, they are unable to make their pay equity adjustments. Broader public sector employers for the most part use the proxy method of comparison. When the proxy method was introduced, the then-NDP government committed to funding these proxy payments at 100%. In 1996 the government attempted to repeal the proxy method from the Act. SEIU Local 204 successfully mounted a constitutional challenge to this attempted repeal. But even though proxy was reinstated in the Act, the government decided it was no longer going to fund these pay equity payments. To the extent that there is a broader public sector in the federal jurisdiction, it would be useful to ensure that new federal legislation expressly commits the federal government to funding pay equity in that sector.
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