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Renumbered on 9/16/2013 as DIR 2013-03.
Office of Federal Contract Compliance Programs
Number: 307 Date: Feb 28, 2013 ADM Notice/Compensation
Procedures for Reviewing Contractor Compensation Systems and Practices.
To outline the procedures for reviewing contractor compensation systems and practices during a compliance evaluation.
Division of Program Operations
OFCCP is issuing this Directive in support of its ongoing policy commitment to address pay discrimination by federal contractors and subcontractors. This Directive specifies the procedures OFCCP field investigators use for reviewing contractor compensation systems and practices. It clarifies and improves OFCCP procedures in further support of the agency's efforts to align pay discrimination enforcement with longstanding principles under Title VII of the Civil Rights Act of 1964 (Title VII).
This Directive is part of a larger assessment of OFCCP's compensation enforcement practices. In 2010, President Obama created the National Equal Pay Task Force, bringing together the Department of Labor (DOL), the Equal Employment Opportunity Commission (EEOC), the Department of Justice, and the Office of Personnel Management to collectively address pay discrimination under their enforcement mandates. The Director of OFCCP, a member of the Task Force, committed OFCCP to review and revise its enforcement guidance and practices to more effectively address compensation discrimination under Executive Order 11246.
This Directive provides clarity and transparency regarding OFCCP practices for all phases of a compliance review. The Directive sets forth in detail procedures for Compliance Officers (COs) to follow in reviewing contractor compensation systems and practices. In keeping with Title VII principles, COs must be able to use a variety of investigative and analytical tools in conducting evaluations. This Directive provides guidance regarding how to apply OFCCP's case–specific approach to addressing all types of compensation discrimination.
Under Executive Order 11246, as amended, and its implementing regulations, contractors may not discriminate in "rates of pay or other forms of compensation;"1 and must review and monitor their compensation systems to "determine whether there are gender–, race–, or ethnicity–based disparities."2 Contractors must maintain records including but not limited to "rates of pay or other terms of compensation."3 During compliance evaluations, OFCCP requests compensation data and analyzes contractors' compensation systems and practices to determine if discrimination exists and, if so, how to remedy it.
OFCCP enforces Executive Order 11246, including the ban on compensation discrimination, consistent with Title VII's flexible, fact–specific approach to proof. This involves factual investigation, data and legal analyses which allow OFCCP to identify and remedy all forms of compensation discrimination. COs tailor the compensation investigation and analytical procedures to the facts of the case as appropriate under Title VII. This case–by–case approach to compensation discrimination includes the use of a range of investigative and analytical tools. Statistical analyses, such as multiple regression, and non–statistical analyses, such as the use of comparators or cohort analysis, are applied as feasible and appropriate given the factual questions and the available data and evidence. COs seek anecdotal evidence, but will investigate and remedy compensation discrimination regardless of whether individual workers believe they are being underpaid, or whether OFCCP has any anecdotal evidence.
This case–by–case approach is designed to eliminate unnecessary barriers to OFCCP's ability to protect workers from discrimination. It ensures OFCCP fully takes into account explanations or responses from contractors, and that OFCCP conducts an analysis tailored to a contractor's compensation systems and practices. Procedures to facilitate thorough and robust investigations are provided in the sections that follow.
The investigation procedures established in this Directive apply to all OFCCP reviews scheduled on or after February 28, 2013, and they apply to open reviews to the extent they do not conflict with OFCCP guidance or procedures existing prior to the effective date. Regardless, the 2006 Compensation Standards and Voluntary Guidelines govern determinations regarding the issuance of an NOV for systemic compensation discrimination in any OFCCP review scheduled, opened or otherwise pending on the effective date of this Directive.
To ensure consistency in implementation, the following terms are defined:
- Base pay – Includes only the designated salary or wages for a position or job title. "Non–base pay compensation" also includes all other forms of compensation such as bonuses, commissions, overtime, and perquisites. (See Compensation.)
- Cohort Analysis – A comparison of the treatment of similarly situated individuals or small groups of applicants or employees.
- Comparators – Similarly situated employees who are outside of the protected class of the individual to whom they are being compared to determine whether a compensation disparity exists.
- Compensation – Includes any payments made to, or on behalf of, an employee as remuneration for employment, including but not limited to salary, wages, overtime pay, shift differentials, commissions, bonuses, vacation and holiday pay, retirement and other benefits, stock options and awards, and profit sharing.
- Control – In a statistical analysis of compensation, using controls is a way of accounting for potential explanations of pay differences. For example, controlling for education accounts for the effect of education on any differences in pay.
- Factors – Elements which are proposed to explain differences in employee compensation under a contractor's compensation system and practices. Factors may be used as controls in a regression analysis or evaluated in a cohort analysis.
- Pay Analysis Group – A group of employees (potentially from multiple job titles, units, categories and/or job groups) who are comparable for purposes of the contractor's pay practices. Regression analysis may be performed on different types of pay analysis groups. A pay analysis group may be limited to a single job or title, or may include multiple distinct units or categories of workers. A pay analysis group may combine employees in different jobs or groups, with statistical controls to ensure that workers are similarly situated.4
- Similarly Situated Employees – The determination of which employees are similarly situated is case specific. Relevant factors in determining similarity may include tasks performed, skills, effort, level of responsibility, working conditions, job difficulty, minimum qualifications, and other objective factors. Employees are similarly situated where they are comparable on the factors relevant to the investigation, even if they are not comparable on others (see Sections 5 and 6 below).
- Summary Data – Compensation data that involves averages or other summaries of worker pay by job title, pay grade, job group, or other category.
- Systemic Discrimination – A pattern or practice of discrimination or an identified employment practice with disparate impact. OFCCP defines a systemic discrimination case as meeting one of two criteria: (a) the case addresses a measurable pattern of discrimination (either based on findings from a regression analysis or based on any other appropriate aggregate analysis of compensation data); or (b) the case addresses an identified practice applicable to multiple employees that results in pay discrimination (such as a practice of steering employees who are members of a protected class toward lower paying jobs at hire). There is no specific numeric threshold used to define a systemic case.
- Base pay – Includes only the designated salary or wages for a position or job title. "Non–base pay compensation" also includes all other forms of compensation such as bonuses, commissions, overtime, and perquisites. (See Compensation.)
When a contractor is scheduled for a compliance evaluation, OFCCP uses the Scheduling Letter to request data and information about the contractor's compensation system and practices. Upon receipt of the data, OFCCP conducts a desk audit. OFCCP may request and review additional compensation data, and conduct an onsite investigation as well as an offsite review of records and data, before making a final determination regarding compliance.5 During the desk audit and at subsequent stages of the compliance evaluation, the CO should communicate with the contractor, as appropriate, in order to ask clarifying questions about the materials submitted, interpret codes or categories used in the data, identify any missing or incomplete information, and request additional information as needed. The CO should obtain all such information as early in the process as possible.
- Summary of OFCCP Compensation Investigation Procedures
Below are procedures that the CO follows in reviewing contractor compensation data and information, however it is important to note that the order in which these procedures occur may vary based on the facts and circumstances of each review. At any stage in the process, OFCCP may determine, based on the evidence, that it is appropriate to close the review or may determine that further review is warranted. Generally, the CO:
- Conducts Preliminary Analysis of Summary Data (if necessary or appropriate)
- Conducts an Analysis of Individual Employee–Level Data
- Determines the Approach from a Range of Investigative and Analytical Tools
- Considers All Employment Practices that May Lead to Compensation Disparities
- Develops Pay Analysis Groups
- Investigates Systemic, Small Group and Individual Discrimination
- Reviews and Tests Factors before Accepting the Factors for Analysis
- Conducts Onsite Investigation, Offsite Analysis, and Refinement of the Model
Contractors have an opportunity to provide clarification of their submissions and to explain their compensation system and practices. The CO conducts a thorough investigation of all potential compensation discrimination issues and makes a compliance determination.
- Conducts Preliminary Analysis of Summary Data (if necessary or appropriate)
- Applying Case–Specific Investigation Protocols
- Conduct a Preliminary Analysis of Summary Data (if necessary or appropriate)6
When OFCCP begins a compliance evaluation with summary compensation data, a CO conducts a preliminary analysis to determine whether to proceed further with the desk audit, including requesting and reviewing individual employee–level data as described in Section 2. A CO may also use the preliminary analysis tools described in this section to assess individual data, by first grouping the data by the contractor's pay ranges or job groups, or may proceed directly to section 2 and analyze the complete individual data. This preliminary analysis, standing alone, is not evidence of discrimination. Results of the preliminary analysis may indicate where further review of compensation data is warranted and assist OFCCP in prioritizing investigative resources.
Prior to conducting a preliminary analysis, the CO reviews the data to make sure it has been provided in the requested format. If a contractor submits summary compensation data based on job groups, titles in those job groups should be consistent with the groupings in the Affirmative Action Plan (AAP). Summary compensation data submitted in a format other than by AAP job group, or the contractor's existing pay grade, level or band system, generally is not acceptable for analysis.
In general, the preliminary analysis assesses quantitative and qualitative factors. Quantitative factors may include:
- The size of the overall average pay difference based on race and gender;
- The size of the largest average pay difference within AAP job groups, or the contactor's existing salary band or pay grade system;
- The number of job groups or grades where average pay differences based on race or gender exceed a certain threshold; or
- The number of employees affected by race–or gender–based average pay differences within job groups or grades.
OFCCP periodically may adjust the size and weight of the factors used for these quantitative comparisons, based on the review of the results of investigations, the results of quality audits, and other factors such as agency resources and priorities.
Qualitative factors may include compliance history, OFCCP or EEOC complaints, anecdotal evidence, potential violations involving other employment practices, or data integrity issues, among others.
Because this preliminary analysis has limited utility for making ultimate determinations of discrimination, OFCCP uses it only to determine whether to continue a compliance evaluation or how to allocate investigative resources. OFCCP does not use preliminary analysis of summary data to limit further compensation data requests or to define the compensation issues OFCCP may pursue in later stages of a compliance evaluation.
After the preliminary analysis, the CO may request that the contractor provide additional information necessary to evaluate compensation issues, including individual compensation data for employees who are covered by the compliance evaluation, other additional data not provided in response to the Scheduling Letter, information regarding the factors used to determine compensation, and information about the contractor's policies and practices related to compensation.
- The size of the overall average pay difference based on race and gender;
- Conduct an Analysis of Individual Employee–Level Data
In any case where individual data is provided or requested, the CO uses the data and information in order to understand the contractor's compensation system and practices and to make compliance determinations. The CO may contact the contractor during the initial analysis of the data to ask clarifying questions about the materials submitted, interpret codes or categories used in the data, identify any missing or incomplete information, and request additional information if it is needed.
If complete compensation data and information regarding the contractor's compensation system and practices are not received in response to OFCCP's request, the CO immediately contacts the contractor to secure the information. If the contractor fails to submit requested data or other compensation information in a timely manner, a Show Cause Notice is issued in accordance with OFCCP procedures as specified in the Federal Contract Compliance Manual (FCCM).
Data that the contractor maintains in electronic form must be submitted in a complete, readable and useable electronic form upon request.
After receiving and reviewing the data and information, the CO continues the desk audit applying the investigative framework described below. The CO records all desk audit findings and pending actions to be taken. The results of the desk audit are used to determine whether the evaluation should continue. If at any point during the process of reviewing data and information, the CO determines either that there is evidence of potential compensation discrimination, or that more data or information is needed to make that determination, OFCCP may proceed to an onsite investigation.7 Closure at desk audit must be consistent with standard OFCCP desk audit procedures.
- Determine the Approach from a Range of Investigative and Analytical Tools
Investigation of potential compensation discrimination presents complex and nuanced issues. The choice of the best approach for a case depends upon the underlying facts, the available data, and the contractor's compensation system and practices. As such, OFCCP takes a case–by–case approach to analyzing compensation issues.
At the early phase of an evaluation, a CO may conduct a preliminary analysis as described above. As a compliance evaluation moves from the desk audit to an onsite investigation and a final determination regarding compliance, OFCCP reviews and refines the approach in light of information provided by the contractor or developed through the investigation. All final determinations of compliance are based on a rigorous, appropriate and legally sound analysis of the facts and data.
A variety of tools are available for investigating and analyzing compensation issues. There is no single tool that must be used in every case. The use of a particular tool, or combination of tools, depends on the facts of the case. COs determine, in appropriate consultation with their supervisors, OFCCP statistical analysts, and the Regional Solicitors of Labor (RSOL), which investigative or analytical tools are used. Other national office experts and personnel, and the National Office Solicitor of Labor (NSOL), may also be consulted.
In every case there are three key questions to answer:
- Is there a measurable difference in compensation on the basis of sex, race, or ethnicity?8
- Is the difference in compensation between employees who are comparable under the contractor's wage or salary system?
- Is there a legitimate (i.e. nondiscriminatory) explanation for the difference?
Upon finding any compensation disparities (differences), the CO conducts an appropriate factual investigation, and gets assistance with data and legal analyses, to address each of these questions. An investigation may include analysis of workforce data and contractor compensation policies and practices; interviewing personnel and employees; examining payroll and Human Resource Information Systems (HRIS); conducting non–statistical analyses, such as comparative and/or cohort analysis, and statistical analyses, such as regression analysis. Investigations may require consulting with statistical analysts and other experts, and consulting with RSOL and NSOL, as well as examining other relevant information.
- Is there a measurable difference in compensation on the basis of sex, race, or ethnicity?8
- Consider All Employment Practices that May Lead to Compensation Disparities
In developing an investigation plan at the desk audit phase, and in applying that plan at each step of the compliance evaluation, the CO should examine all employment practices that have the potential to lead to compensation disparities. This covers examination of the compensation system, including base pay and non–base pay data, and other practices as well.
The CO should examine employee access to opportunities affecting compensation, such as: higher paying positions, job classifications, work assignments, training, preferred or higher paid shift work, and other opportunities. The CO should also examine policies and practices that unfairly limit a group's opportunity to earn higher pay, such as "glass ceiling" issues, and access to overtime hours, pay increases, incentive compensation, and higher commission or desired sales territories. The CO may investigate any observed differences in pay, other earnings or benefits, job assignment/placement, training/advancement opportunities, differences in opportunities to increase compensation, or other unexplained differences.
The CO should tailor the approach and tools to be used based on the contractor's compensation practices. Differences may be observed with regard to base pay; job assignment or placement; opportunities to receive training, promotions, and other opportunities for advancement; earnings opportunities; and differences in access to salary increases or add–ons, such as bonuses.
In order to evaluate compensation differences beyond base pay, it may be necessary to make an additional data request regarding the contractor's compensation system and practices or to go onsite.
The CO should consider the nature of the job(s) in question when determining the tools to be used to investigate and analyze the compensation data and information. A commission sales position, for example, is examined differently than an entry–level, hourly rate position. High level professional and managerial positions should be examined to determine if "glass ceiling" issues exist. (See FCCM – Corporate Management Compliance Evaluations.)
The following table contains examples that illustrate differences in employment practices that may lead to compensation disparities warranting review and investigation for potential discrimination:
Compensation disparities warranting review and investigation Type of Difference Basis for Comparison of Employees Examples of Differences Differences in Salary or Hourly Rate Similar job, different pay Hispanic customer service agents are paid less than white employees in the same or similar positions due to highly subjective salary system. Differences in Job Assignment or Placement Similar qualifications, different job Women hired into entry–level grocery store positions are disproportionately assigned to the bakery department. Men are assigned to the meat department where pay and promotion opportunities are better. Differences in Training or Advancement Opportunities Similar job, different opportunities to increase skills Employees may participate in a management training program on a recommendation by a manager. Certain managers are referring only white males resulting in disproportionate participation. Resulting promotions to management positions are disproportionately awarded to white males. Differences in Earnings Opportunities Similar job, different earnings African–American sales workers are disproportionately assigned to territories with less potential. Differences in Access to Increases and Add–Ons Similar job, different opportunities to increase pay Female lawyers who get exactly the same base pay as male counterparts earn less on annual bonuses.
- Develop Pay Analysis Groups
At this stage, the CO has reviewed the data and information submitted by the contractor. The next step in the analysis, if the data allow, is to develop pay analysis groups that are used to test for statistical significance on large groups of employees. The analysis may be based on groups that are larger than individual job titles and AAP job groups. By combining employees into appropriate pay analysis groups, using statistical controls as necessary for title or level, OFCCP is able to more easily identify potential systemic discrimination needing further investigation and potential remedy. Individual or cohort comparisons may be conducted, as warranted, as shown in Section 6. If the data allow, OFCCP analyzes pay disparities based on protected class status that cannot be explained by neutral job–related factors, e.g., identifying potential placement or classification issues for further investigation.
Analytical Model – The CO determines the pay analysis groups to be used in the analytical model, consulting as needed with their supervisors, the statistical analysts and RSOL. (COs may make preliminary determinations that are then refined with the assistance of the statistical analysts and RSOL.) A pay analysis group is a group of employees (potentially from multiple job titles, units, categories and/or job groups) who are comparable for purposes of the contractor's pay practices. Regression analysis may be performed on different types of pay analysis groups. A pay analysis group may be limited to a single job or title, or may include multiple distinct units or categories of workers. A pay analysis group may combine employees in different jobs or groups, with statistical controls to ensure that workers are similarly situated. Statistical testing applied to practices that impact pay such as job assignment may require a different analytic grouping than tests for within job pay differences.
OFCCP develops pay analysis groups by considering elements such as: the particular industry, the types of jobs and compensation at issue, the contractor's actual compensation practices, and available data. Compensation practices may differ by role (e.g., executives, managers, supervisors and individual contributors), by level (with higher–level employees tending to receive additional or alternate forms of compensation), by function (such as sales employees who are paid on commission), by unit (department, division, location, etc.) and/or by job classification (exempt or non–exempt, part–time or full–time, bargaining unit, etc.). This information may be found through a review of the contractor's compensation policies or training documents, description of its compensation system or practices, compensation data, records and coding, job descriptions, and interviews. COs may consider other facts relevant to determining groups, such as the ability of workers to rotate or transfer among different positions within a business unit, a common hiring or selection process, a common performance review practice or other common identifiable employment practice related to compensation.
Initially, the CO combines jobs into appropriate larger pay analysis groups, which may include multiple job titles or units, that are comparable for purposes of the contractor's compensation practices. The combination of job titles or jobs is based on what the CO knows of the contractor's compensation system and its practices. Where a combination of job titles or jobs at multiple levels is used, it may be appropriate to statistically control for title and level within the pay analysis group. The size and definition of a group, and whether to include title or level as a control in the analysis, depends on available data and evidence and the compensation practices being analyzed. Reasonable differences may exist among workers in a pay analysis group as long as these differences are properly accounted for in the statistical analysis to be conducted. OFCCP conducts regression analysis on the pay analysis groups to determine whether statistically significant disparities in compensation exist.
The CO also develops pay analysis groups that evaluate broader pay differences based on protected class status that cannot be explained by neutral job–related factors, e.g., assignment, placement or classification issues. Statistical testing for practices that impact compensation such as job assignment may require a different pay analysis group than tests for within job compensation differences.
The analytical model developed by the team (OFCCP investigators, statistical analysts, and RSOL) is used to initially test large pay analysis groups. As the results of the initial analysis and facts warrant, OFCCP refines the analysis, based on pre– or post–onsite information, and OFCCP may conduct subsequent statistical and/or non–statistical tests of smaller groups or individuals.
If possible, the CO develops and applies the model to the data at the desk audit phase, using preliminary determinations regarding appropriate pay analysis groups. If the CO needs more data or information to develop the groups, or conduct or refine the analysis, the CO may proceed to an onsite investigation before performing the analysis. If it is not possible to form pay analysis groups or perform a regression analysis at the desk audit phase, the CO also may use preliminary tests or broad indicators of potential compensation issues at the desk audit to identify pay practices or issues needing further review. As a compliance evaluation moves from a desk audit to an onsite investigation and a final determination regarding compliance, COs review and refine the approach, including the determination of the appropriate pay analysis groups, in light of further information provided by the contractor or developed through the investigation.
Investigate Systemic, Small Group and Individual Discrimination
The CO investigates possible systemic, small group and individual compensation discrimination as indicated by the initial analysis of the compensation data and information (see illustration below). Pay analysis groups are developed to examine possible systemic issues. Systemic discrimination may be a pattern or practice of discrimination or an identified employment practice with adverse impact. When the CO completes the analysis of larger pay analysis groups, or in cases where the data are inappropriate or insufficient for regression analysis, the CO may examine the data to address possible compensation discrimination involving specific job titles, particular units or locations.
After analyzing the data for potential discrimination in larger and/or smaller pay analysis groups, the CO may conduct comparative analyses of small groups or individuals to determine if pay disparities exist, and if there is evidence sufficient to support an inference that pay differences are due to discrimination.
The mere fact that there are pay differences between comparators, without any other evidence of pretext or other indicia of possible discrimination, generally is not sufficient to find a violation of E.O. 11246. Individual or small group pay disparities typically are analyzed under the disparate treatment theory of discrimination.
In conducting a small group or individual analysis, the CO starts by determining if there are similarly situated employees who are comparable to the affected small group or individual. The CO then conducts a comparative analysis, or cohort analysis, to examine the treatment of similarly situated individuals or groups of applicants or employees.
The determination of who is similarly situated is case–specific. Who is similarly situated for purposes of an individual analysis or review of a single specific employment decision may be determined based on different criteria than when conducting a systemic discrimination analysis. For purposes of evaluating compensation differences, employees are similarly situated where it is reasonable to expect they should be receiving equivalent compensation absent discrimination. Relevant factors in determining similarity may include tasks performed, skills, effort, level of responsibility, working conditions, job difficulty, minimum qualifications, and other objective factors. In some cases, employees are similarly situated where they are comparable on some of these factors, even if they are not similar on others. For example, when evaluating a job assignment issue, workers are similarly situated when their qualifications are comparable, but they are assigned to jobs at different levels.
In conducting a comparative analysis, it is also necessary to obtain data and information specific to the individuals or small groups that are being compared. If the contractor has not already provided such information, the CO requests the relevant available information. This information may include applications, personnel files, performance ratings, compensation histories, etc. The CO may determine that an onsite investigation is necessary to fully examine any potential discrimination issue.
Review and Test Factors before Accepting the Factors for Analysis
The CO evaluates information from the contractor regarding the factors the contractor considered in making compensation decisions. As in any investigation, the CO must evaluate whether the factors are implemented fairly, consistently applied, and relevant to the contractor's compensation practices before accepting them as appropriate for inclusion in the analytical model and/or comparative analysis. OFCCP considers all relevant factors offered by the contractor to determine whether these factors, in conjunction with other legitimate factors, if any, actually explain pay, are implemented fairly and consistently applied, and whether they should be incorporated into a statistical analysis, on a case by case basis.
A factor is an element that the contractor offers to explain differences in employee compensation under its compensation system and practices. A factor may be a qualification or skill that the worker brings to the position such as education, experience, etc. It may also be an employment element such as position, level or function, tenure in position, performance ratings, etc.
When using factors as controls in a regression analysis, the statistical analyst tests the factors to make certain they are predictive for pay and that the factors are not potentially tainted by discrimination.9 The statistical analysts and OFCCP investigators work together, and consult with RSOL as needed, to determine what factors to include in the final analytical model. When conducting a comparative analysis, the CO likewise evaluates factors offered by the contractor as to their relevance to compensation and whether they were consistently applied.
In testing the offered factors, the CO first determines if the data are complete and accurate. Second, the CO determines if the factor is relevant to compensation in terms of the contractor's policy and how it was applied. Third, the CO determines whether the factor was consistently applied by the contractor. Fourth, the CO determines whether using the factor presents adverse impact issues.
Where identified employment practices such as performance review systems show disparities, COs should proceed to review for potential evidence regarding whether the practices result in disparate treatment or disparate impact – including inquiring about evidence of validation and/or the existence of best practices to reduce adverse impact.10
In addition to analyzing data regarding the offered factors, the CO should review policy statements and other documentation addressing how the factors are considered. When conducting an onsite investigation, the CO should conduct interviews with contractor staff and employees to verify how the factors were applied in making compensation decisions, and document the results consistent with the FCCM and other OFCCP procedures.
Conduct Onsite Investigation, Offsite Analysis, and Refinement of the Model
Upon completing the previous steps, OFCCP investigators, statistical analysts, and RSOL decide on a preliminary analytical model having considered all available and relevant information regarding the contractor's compensation system and practices. At this stage, the contractor is given an opportunity to timely provide any additional relevant information to be considered. If that additional information adequately resolves or explains the disparities, consistent with the framework set forth above, the CO concludes the investigation. Otherwise, if an onsite has not yet been conducted, the CO determines whether an onsite is needed.11
The CO informs the contractor in writing of the onsite visit. The CO identifies and requests any needed data and information consistent with OFCCP procedures. The CO also discusses the need for interviews with contractor staff members and employees. Any information obtained as a result of the onsite visit and interviews is examined to determine whether the analytical model needs to be refined. For example, data and information obtained during interviews confirms that a factor offered by the contractor to explain a disparity in pay was not consistently applied and resulted in a disparity affecting women. The team refines the model based on the finding that the factor is not a legitimate predictor of pay and should not be incorporated in the statistical analysis.
Refinements to the analytical model and/or determinations of the need to conduct additional comparative analyses are made in accordance with this guidance and Title VII principles. The CO consults with their supervisors, the OFCCP statistical analysts and RSOL, as appropriate, before making any refinements to the analytical model to be used. All appropriate analyses are conducted and the findings evaluated.
- Conduct a Preliminary Analysis of Summary Data (if necessary or appropriate)6
- Concluding the Review and Analyses:
Upon completion of the compliance evaluation OFCCP determines whether there are findings of compensation discrimination.
Based on complete and thorough factual investigation and data analysis, and appropriate assistance with legal and statistical analysts from RSOL and National Office statisticians, OFCCP takes the action(s) the findings warrant. The CO evaluates all available evidence before making a determination regarding contractor compliance. Generally, because a compliance evaluation also includes the investigation of other types of possible discrimination (e.g., hiring, terminations, promotions) any findings of compensation discrimination are addressed along with the other findings. Action may include closure of the compensation issue if no violations are found, or issuance of a Notice of Violation (NOV), as appropriate. At this stage of the compliance evaluation, the CO documents all findings.
- Summary of OFCCP Compensation Investigation Procedures
The Freedom of Information Act (FOIA), 5 U.S.C. 552, applies to all information/data submitted pursuant to this Directive. Upon receipt of a FOIA request, OFCCP evaluates all information submitted by contractors pursuant to the public inspection and disclosure provisions of FOIA and the Department of Labor's implementing regulations at 29 CFR Part 70. OFCCP requires that a contractor affected by a FOIA disclosure request is notified in writing and no decision to disclose information is made until the contractor has an opportunity to submit objections to the release of the information. Moreover, OFCCP does not release data obtained during the course of a compliance evaluation until the investigation, and all subsequent proceedings, if any, are complete.
At 41 CFR § 60–1.20(f), the regulation provides in part that if the contractor is concerned with the confidentiality of information such as lists of employee names, reasons for termination, or pay data, then alphabetic or numeric coding or the use of an index of pay and pay ranges, consistent with the ranges assigned to each job group, are acceptable for purposes of the compliance evaluation. Regardless, the contractor must provide full access to all relevant data pursuant to 41 CFR 1.20(a)(1) and § 60–1.43.
This Directive does not create new legal rights or requirements or change current legal rights or requirements for contractors. Executive Order 11246, as amended, Section 503 of the Rehabilitation Act of 1973, as amended, the Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended, OFCCP's regulations at 41 CFR Chapter 60, and applicable case law are the official sources for contractors' compliance responsibilities. Nothing in this Directive is intended to change otherwise applicable laws, regulations or other guidance or to restrict or limit OFCCP's ability to perform compliance reviews, request data, or pursue enforcement of any issue within its jurisdiction.
Holders of ADM and LEG Binders: File this Directive in your Administrative Practices Binder.
District and Area Offices EOSs and EOAs: File this Directive behind the tab for ADM Directives in your FCCM Binder.
A, B (both hard copy and electronically); C (hard copy only).
This Directive remains in effect until OFCCP determines it needs to be revised or rescinded.
- SIGNATURE: Patricia A. Shiu, Director, Office of Federal Contract Compliance Programs
2 41 CFR §60–2.17(b)(3); see also 41 CFR §60–2.17(d).
4 Statistical testing applied to practices that impact pay such as job assignment may require a different analytic grouping than tests for within job pay differences.
5 The Paperwork Reduction Act (PRA), 44 U.S.C. Chapter 35, does not apply to this Notice because it does not involve any collection of information subject to the approval of the Office of Management and Budget. To the extent information is collected during the desk audit, it is covered by OFCCP's Scheduling Letter. To the extent information is collected during an OFCCP investigation, it is exempt from the PRA. 5 CFR 1320.4(a)(2) (The PRA does not apply to information collections during an "administrative action, investigation, or audit involving an agency against specific individuals or entities.")
6 OFCCP may begin a desk audit with summary compensation data, by pay grades or ranges and by race and gender, at the beginning of a compliance evaluation. When OFCCP receives individual employee–level data at the beginning of a compliance evaluation, a CO may proceed directly to Section 2 or may conduct preliminary analysis of the individual data first.
7 This includes a situation where the compensation information provided at the desk audit does not include individual employee–level data and/or the data is not complete, accurate, readable or useable for analysis.
8 In situations where there is sufficient data to use regression analysis, a measurable difference generally means a statistically significant difference, two or more standard deviations, consistent with Title VII principles. In the situation of disparities in small group and/or individual compensation, a measurable difference and sufficient evidence will be determined in conformance with Title VII principles (see Section 6 below). Regardless, statistical evidence is not required in all compensation cases; other evidence may be used to evaluate potential discrimination in pay.
9 Where statistical testing identifies evidence that a factor results in adverse impact, further investigation may be needed to determine whether it is appropriate to incorporate it into the model.
10 Relevant questions may include whether rating criteria have been confirmed to be job–related, whether raters are trained and participate in calibration sessions, whether multiple raters are used, whether there is any higher level review of ratings, whether analysis of ratings by race, sex, and ethnicity is done and whether there is an appeals process in place.
11 The determination of whether an onsite visit will be conducted will be made consistent with the FCCM and other applicable OFCCP procedures (including Directive Number 295, Active Case Enforcement procedures, December 16, 2010).


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subset: commoncrawl


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Coconut oil makes this cake dairy free, similar to my "Bran" muffin recipe, the honey and coconut oil combination creates a really moist, sweet, delicious taste. You can taste the coconut oil flavor, so grapeseed oil or a vegan margarine might be a better option if the tropical goodness is not your thing. And, of course, you can always substitute butter if you don't need this to be dairy free.
Against All Grain has a recipe for Apple Spice Coffee Cake that uses cinnamon and cardamom
Healthy Green Kitchen made Italian Apple Cake with a dreamy review of a Tuscan cook book
Pitcher and Plate has a recipe for Chunky Apple Cake using cinnamon and coconut milk
Opera Girl Cooks made Spiced Apple Honey Cake with pecans and raisins
And Elana's Pantry has a recipe for Cinnamon Apple Cake that is less sweet and uses OJ and agave
Apple Cake (Gluten, Grain, Sugar & Dairy Free)
serves 8
4 eggs
1/2 C honey
1/2 C coconut oil melted
1 C peeled, diced apple pieces
3 C blanched almond flour
1/2 tsp salt
1/2 tsp baking soda
Preheat the oven to 350
Prepare your baking dish:
- line a round springform pan with parchment paper on the base, trim the excess
- close the springform pan and butter the sides and the parchment covered base, set aside
Prepare the apple pieces:
-peel, quarter and deseed a sweet, crisp apple (I loooove honeycrisp)
-slice into 1/4 inch slices
-halve each slices and then cut into pieces (this way your pieces are square and not rectangular)
-measure 1/2 a cup (about 3/4 of a good sized apple)
Whisk the eggs, honey and cooled, melted coconut oil
Mix the apple pieces into the whisked, wet ingredients
In a separate bowl, mix the blanched almond four, salt and baking soda
Mix the dry into the wet ingredients, blend well
Pour into the prepared springform pan
Bake around 45 minutes, maybe a little longer but watch for too much browning
Remove from the oven and let cool 30 minutes to an hour
Don't worry if your cake sinks in the center, this is a dense and heavy cake
Slice into triangles and serve


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Reducing losses at harvest requires a combination of due dilligence and attention to agronomic conditions.
Take time to effectively calibrate your yield monitor to assess performance. An accurate and reliable data set will prepare you for success next year.
Make sure that moisture is available for harvest. Overly dry seeds risk injury and shattering during harvest.
Check that the correct settings are in place for all equipment. Improper reel speed and position can lead to shattering and large yield losses.
Select the proper thresher speed. A slower threshing speed can decrease threshing severity and minimize split damage.
Limit forward speed to 2.5 to 3.0 miles per hour. Slower speeds can reduce shatter and stubble losses and maximize yield potential.
Green stem syndrome can cause significant yield loss. To manage, it may be necessary to wait until after a killing frost if possible.
Stress at different times during soybean development can have various impacts on soybean appearance, such as wrinkled seed coats and green beans.


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Gardening—you should excuse the pun—is rapidly growing into a top hobby. Maybe we're trying to save money by growing our own vegetables or maybe gardeners are returning to the soil as a means of working off stress. Whatever the reason, gardening is one of the most "fruitful" returns on investment one can make.
Unfortunately, novice gardeners can end up spending more on seeds, tools and the other doodads required for a start-up patch. The good news is there are a few tricks that can save you money while still turning out a good crop. Here are nine tips to get you going.
1. Plan Early
Plot out your garden before turning the first spade of earth. Several websites make it easy to plan your garden either at no cost or free for the first 30 days. I'm particularly partial to GrowVeg.com, which helps you plot out the amount of space you'll need for each plant and where each should go in relation to other plants. The Farmers' Almanac is still one of your best guides to when you should start planting and what kind of weather you can anticipate for the growing year.
2. Understand Your Land
Before you shell out a ton of cash for new plants, ask your neighbours what plants thrive in the soil of your region. Keep in mind plants appropriate for your growing zone might not work in your garden due to variations in soil composition, microclimate, pests, sunlight exposure and water availability.
3. Dig Deep
Digging a deep garden bed can increase the number of plants you grow and ensure roots have plenty of room to grow.
4. Mulch
Mulching your garden—or covering the surface layer with plastic, wood chips, etc.—will feed the soil, keep the soil and plant roots cool, retain moisture to reduce watering and prevent weeds. Mulching also will cut down on the amount of time you spend watering and weeding.
5. Plant From Seeds
Starts are 10 times more expensive than seeds and often are sold long after the plant should have been unpotted. (Never buy starts with roots growing through the bottom of the pot.) Starting seeds indoors is cheaper and will give you a jump on the season. Save even more money by creating your own seed-starting pots.
6. Save and Swap Seeds
Seed packets often contain far more seeds than you actually need, so consider starting or joining a seed exchange in your area. You can also harvest and store seeds for use the following year.
7. Profitable Plants
If you have limited space, consider planting produce that costs the most in a store or at a farmers' market. Monetarily, you get the best bang for your buck by growing cilantro, salad greens, chives, tomatoes and squash.
8. Be Sun Savvy
You'd be surprised how often experienced gardeners put a shade-loving plant in full sun or a sun-loving plant in the shade. Daylight is a moving target, so it can be difficult to ascertain the best location for each plant. Before plotting out your garden, spend some time studying the movement of the sun over that patch of land, paying particular attention to those areas that are heavily shadowed.
8. Smart Watering
Consider installing an Eevapotranspiraton (ET) Controller, if you have an in-ground sprinkler system. These systems use real-time weather data sent by satellite to control when your sprinklers turn on and off. This can cut your water usage by up to 30 per cent. Controllers costs between $300 and $400, depending on system size.
9. Install Drip Irrigation
If you don't have an in-ground sprinkler system, consider installing a drip-irrigation system. You'll save on water bills because the water won't evaporate as quickly and plant roots will receive a more thorough soaking.


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Five steps to start planning summer fun
In Minnesota, summer is often long awaited—with an anxious countdown to sunshine, warm weather and time to take in the natural beauty that surrounds us.
However, in February and March, when summer's long days are still firmly in the future, it's time to plan and sign up for activities and programs that keep kids engaged and entertained for 12 weeks of summer fun.
Try these five steps for planning a summer that's sure to be a smash-hit:
1. Start with goals
Begin the planning process by outlining your family's priorities and goals for your child this summer. For example:
- Do you need part- or full-time childcare for little ones?
- Is your child ready for camp?
- Is your child interested in learning a new skill or hoping to improve an existing talent?
- Are you hoping to ensure your child gets off the couch or away from screen time?
- Would your middle schooler benefit from gaining more independence or leadership experience?
- How can you structure a memorable summer without feeling like a taxi driver?
2. Schedule a family brainstorm
Next, get your kids involved in designing their summer. Start the brainstorm by explaining the goals and priorities for the season, and then let the creative ideas flow.
Ask children to make a list of the activities, topics, subjects and concepts that interest them. Encourage ideas that involve them independently and those that include the whole family. Here are just a few examples:
- Do projects like writing a short story or creating a photo book
- Invite friends to enjoy a neighborhood playground and picnic
- Learn about space and stars
- Plant and care for a garden
- Play sports
- Sandcastles and swimming at the beach
- Spend time as a family outdoors
- Visit the zoo, a museum or state park
- Check out weekly themes for Summer Power in the Twin Cities metro and in Rochester for Summer Power and see which interest them
After the initial brainstorm, create a bucket of ideas that can be added to every time someone says, "You know what we should do this summer …"
3. Gather more ideas
Supplement your family's bucket of ideas by connecting with your peers. Has your friend had a good experience sending their child to horse camp? Does your child have a friend that they'd like to do a summer program with this year? Ask around.
You can learn more about options for kids this summer at events like:
- Minnesota Parent's Camp Fair on February 24 from 10am to 2pm at the Como Park Zoo and Conservatory
- Summer Programs Fair on March 3 from 9:30am to 12pm at your local Y
4. Pick the ideas for this summer
By now, your idea bucket should have plenty of options for a fantastic summer. Revisit your goals and sort through the ideas to determine the items you'll do as a family and the activities kids can do on their own.
There's a good chance the list of ideas will be longer than what you can realistically tackle this summer. Save these ideas for use throughout the year.
5. Mark your calendar
Create a calendar that the whole family can see with this year's summer vacation, family fun and just-for-kids activities. Use whatever works best for your family—whether it's a shared online calendar, a big sheet of paper in the kitchen or a monthly markerboard.
It's not critical to plan every individual activity for each day of summer, but perhaps you can block the calendar with items like, "at-home activity" or "family excursion" that can work with your bucket of ideas when the day comes.
And don't forget to take time for yourself—make time in the schedule for needed breaks where you can focus on an activity that's just for you.


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Legal Question in Criminal Law in Texas
I was involved in an altercation with a family member and was issued a protective order on me. I since have reconciled with the person and have had contact with her on many occasions. She has tried to go have the order removed with no luck. It seems like theres nobody who can gives us the proper guidance to have this order removed. If i could just get a stepping stone and start from there it will be greatly appreciated. The order is issued in Hidalgo, County Texas. Also, i travel to Mexico alot and have had difficulties upon entering The US because of this order. Could this have to do with the fact that i was released on bail when this incident happened and if so how could i have that removed as well.
1 Answer from Attorneys
I am affraid that you will have to retain an attorney to do that for you. Good luck and God bless you both.
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Anovite provides you a unique way to earn income while enriching your health with life changing products. We offer support to our clients with marketing materials, training videos, and samples to help you live a life on your terms.
This husband and wife team have combined several decades of experience in network marketing. Along with Gino's 20 years' experience as an international speaker and copywriter teamed up with Brandy's direct sales background and love for technology, they developed a deep desire to teach and shorten anyone's learning curve in network marketing. They truly value the relationships they cultivate and watching others rise to success. The full-time income that they have created with network marketing has opened their time to help others follow their dreams and spend more time with their family. When they're not masterminding the next phase of support for their team, you'll find them playing with cars and motorcycles on the open Arizona roads.
Everyone starts by CHASING the dream, but this couple, working together, are now LIVING the dream of financial and time freedom using our Anovite model of Leveraged Income. Ray used to be a janitor cleaning floors and toilets, and in 1994 was homeless, but through MLM, grew his team to 850,000 people, earning ten million dollars with one company—and now with Narine, is doing it again with the superior Anovite products. Deeply disturbed by the "holocaust" of rampant disease with millions tragically dying before their time, they are on a passionate crusade to educate, inspire, save and enrich the lives of one million people, both physically and financially. They believe in the "win-win" philosophy, that the more people you HELP, the HAPPIER you will be. "Mission before Money ~ People Before Profits"
My name is Sheila Sowell and my husband is James. We are just simple grandparents that love the Lord and put Him first and family second. Everything else just falls into place. Since 2007 I have been a stay at home wife to help my husband fight through his first of 3 battles with cancer and have also been raising four of the most precious grandchildren over the last 10 years and have struggled to provide for my family like many people out there. I have always had a heart to help people and do for others. I am so excited to be a part of Anovite' and be able to reach and help so many with their health and wellness through these amazing products. I seek to help those individuals and families who have had a negative turn in life, in their wellness and in their finances. I want to share the opportunity that can help them start over fresh and fill the barrel and give them life and hope back!
Darla Martini, along with her husband are the founders and lead pastors of The Hub in Central Arkansas. She has been a dynamic force in the beauty industry in Arkansas since moving to the area from Southern California twenty years ago. She has spent her life as an entrepreneur, motivational speaker, and trainer spanning many industries and innovations. When faced with her own health issues 15 years ago she began the search for something pure and organic. With training in the health and wellness industry from her first business, she knew immediately that not only had she found the answer she needed for her and her family's health, but drawing from her business knowledge, she knew she must launch this company into her home state of Arkansas. With the help of Anovite' Darla now has ample time and finances to spend with her family, travel as a motivator and business builder for her business, and ministry. She is a firm believer team work makes the dream work and that is evident in the fast growth of her team. Her vision is to see lives changed.
Dave and Beth Ober have been married for more than 33 years. They have 5 children and 6 grandchildren and live near Hershey Pa! Dave graduated with an A.S.B. degree in Business Administration from Central Penn Business College in 1985 and has been self employed since 1989. Dave and Beth's entrepreneurial spirit has taken them from a small business to over 150 employees. Dave was also named Business man of the year by the National Congressional Committees Business Advisory Council, completed the Robert Rohm speakers boot camp and named twice in the Who's Who of Executives and Professionals for Business Growth and Entrepreneurship . Dave and Beth have been students of Leadership and Personal Development since the late 1990's and has been mentored by some great leaders such as Charlie Tremendous Jones, Orrin Woodward and Robert Rohm. Dave and Beth have a passion to help others find a better quality of life and health through these amazing products and are so grateful to be a part of this great company and community of awesome people!
Lisa Coots and her husband Jimmy have been married for 34 years. They have 3 children and 10 grandchildren and live in Clinton, Arkansas. Lisa & Jimmy love the Lord and their family and give God all the Glory for his Goodness and Grace throughout their lives.
Lisa has been in full-time ministry since 2001. She is a dynamic Speaker, Leader and Mentor. She has a BS in Psychology and even though she is new to the MLM industry, Lisa is a Rising Star in Anovite and has built an incredible team within her first year. She has a Big Heart for others and loves to help people. She enjoys helping folks gain greater health and wellness through these phenomenal products.
Lisa is known as the "Come-back-Kid" of Anovite as she came out of the gate running strong when she first started in her business in October 2017, but just 3 months into her new launch, she hit a "pause" button in life when her mom was diagnosed with Stage 4 Cancer. Four months later, she came back into Anovite full-time and started rebuilding her business. With her warm market now gone, she had to find new ways to generate leads and has been nicknamed the "Come-back-Kid" as she worked diligently to bounce back from her absence and her downline continues to boom today. In Business, Lisa calls herself "The Hope Dealer" as she deals hope through Anovite and her personal relationship with Jesus Christ everywhere she goes.
Besides being in Anovite, Lisa enjoys spending time with her family. She and Jimmy stay busy with their 3 children and 10 grandchildren. Lisa also maintains a busy schedule with her ministry as she travels the Country both by herself and with a ministry team as a Leader, Prophetic Encourager and Motivational Speaker.
Dennis grew up on a farm in Indiana and learned that dedication, hard work, and persistence pays off. He loves nature and the great outdoors. He has been in the MLM industry for 30 years. He has been studying health and fitness since the age of 12 and is fascinated how the body works and how to keep it healthy. After losing his health 30 years ago due to being an aluminum welder and having a very stressful job, the search to regain his health began. He went to many doctors and tried an incredible amount of health products with minimal results. No matter what he tried he wasn't able to balance his immune system and regain his health till he got on the Anovite products. He finally found the company he had been searching for a long time. Dennis has the entrepreneur spirit and he dreamed of having a home-based business with a stellar company that had stellar health products. His mission to help people regain their health and improve their finances is finally being realized. He loves reading, personal development, learning leadership skills, and leading by example. He strives to be the leader that his team has been searching for. With his love for helping people succeed, it's all coming to fruition. Thanks to Anovite, he finally found his home in MLM.
I was raised in the construction and cattle industry & believed hard work was the answer to everything. Rachette was one of seven girls and also raised w/ a strong work ethic. After losing their home to a fire, she and her sisters helped rebuild their home from the ground up. The Bible speaks of being equally yoked and that pretty much sums up our relationship. The day we met we realized we shared the same goals and dreams.
We wanted to be financially free & make a difference in people's lives in a positive way. We went to work in the construction industry because that is what we knew, 10 years rolled by and we realized that we were getting by but not really getting a head and most of our friends were in the same boat. Einstein's definition of insanity is doing the same things and expecting a different result. We realized hard work was part of the equation, but without the right vehicle you might never reach your destination. A successful friend shared with me one day, "Instead of just getting paid on what you do I'm gonna show you how to get paid on what you start." He shared the concept of network marketing and even though we didn't fully understand everything, we saw an opportunity for our family to truly reach our goals and dreams and live life on our terms. We got started & made every mistake you can make and were still blessed to replace our incomes in the 1st year. We went on to become multi million dollar earners in this industry. We realized the true power of building a team and by helping others reach their goals and dreams, you will reach yours.
We believe there's nothing wrong with success at the service of other people. Our family has been blessed beyond measure & we truly live the life we always dreamed of living. We look forward to helping you do the same.
58 years ago Tommy & Linda's journey together began. They had seven daughters and after losing their 4th daughter to cancer at the age of 3, Tommy had to leave his passion of teaching and coaching and start a traditional business to pay all the medical bills. Tommy worked 6 days a week, went to church on Sunday and choir practice on Wednesday night. That was his routine for over 30 years. He says he didn't really own the business, it owned him. Nearing retirement age he realized that although he had provided well for his family all those years he had very little to retire on.
He has always been open minded about opportunity and was intrigued with the possibilities of network marketing. When his daughter and son-in-law, Shannon & Rachette Pardue shared with him an opportunity to get healthier and create the retirement income he was looking for, he jumped in and never looked back. A few years later he was able to retire with a 6 figure income & has helped others do the same.
In just 2 weeks on the Anovité products he felt such a difference he knew he had to share with everyone he cared about. They both agree Anovité has the most amazing superfoods on the planet, coupled with a simple business model and support system that allows anyone to reach their goals and dreams! Tommy says "Joining the Anovite family is one of the best decisions we ever made & we wish for everyone to be able to live the life we have today"
Randy and Karon are two people who love life! Both are very active in their church and community. They have a deep conviction to serve the Lord and to help others. Randy serves on several boards and Karon leads the singing at the church they attend. Both are avid outdoorsmen. They have 4 children. Seventeen years ago they were blessed to raise their grandson and then six years later were doubly blessed to raise another grandson! Hayden and Cody are their WHY!
Both randy and Karon are business owners. Randy retired from Kroger after 41 years as District Manager over the meat departments in the Delta Division. They own two retail businesses and it was at one of these businesses that a friend shared with them this business.
After only three short months, they saw more income coming in with this new business than they had during the same time frame with the retail businesses!
They saw an opportunity to not pay overhead! They saw a way to build a business and help others along the way. I They saw a better way of health and wealth! They saw an opportunity for freedom. Freedom to spend quality time with their boys. All they had to do was to share their story and if you meet Karon then you'll soon find out she has no problem talking!! For her it was a "piece of cake"!! When something works then you don't mind talking about it. The amazing results from using these products and the financial results have literally been a game changer. Both Randy and Karon are experiencing a more youthful quality of life, one that is essential in raising two boys!
Today Randy and Karon have an extended Anovité Family and are adding to it daily!
"I was born and raised in the hood of south Louisiana. Never got into trouble but that's just where my grandmother's house was. I went to college because of a football scholarship which is where I met and married Shandra. I was pretty good at football and had big goals and dreams because I thought I was going the NFL. Well, that went away when I didn't make it pro. I started my coaching career and it didn't take long to realize my paycheck didn't represent passion. I was living check to check."
Because of his athletic and coaching background, Quarvay and his wife Shandra Winbush were blown away when they learned of the Anovite company. Although This couple has seen success in the MLM industry becoming industry leaders while making a high six figure income, they were super excited to join Anovite because of the significance of the products, potential success for all within the dynamic compensation plan , and the warm family feel of the people involved. Since kicking off their business in January of 2019, Shandra and Quarvay are climbing the ranks and have become Presidential Founders. When they are not building their business, Quarvay coaches and mentors young men and Shandra enjoys time with her family!!!
We are Wayne and Tina Shrock we are the parents of 4 biological children, 2 adopted children, and Pa and Nana to a grandson.
We both are country kids that believe in putting God first and that he will take care of our needs; not always on our time but his time which is always perfect. We believe in working hard at whatever is set before us. Wayne has been an over the road truck driver and has done construction work most of our married life (which God has granted us 27 years of). I have been a stay at home mother for most of those years.
We were not really looking for a health and wellness business, but it kind of found us. We found help through a product that was marketed through the MLM industry and met our leaders and mentors, Shannon & Rachette Pardue. We felt like God brought them into our lives when He knew we needed them the most. We have found Anovité and feel blessed beyond measure to be a part of a company that has such POWER PACKED products, at an affordable price, and with an owner of integrity and heart for helping people.
Each of these distributors have demonstrated a desire to build a full-time income with Anovite and have proven this desire by building a solid foundation. To be a member of the Six Figure Club, each distributor must achieve a 'Paid As Rank' of Bronze Director at least twice in the last 8 weeks.
Distributors who achieve membership into the Six Figure Club will be recognized and promoted by the company and are required to participate in such promotion as the company deems appropriate which may include travel and appearances, website pictures, bio's, etc. Travel costs would be reimbursed by the company, within reason, determined by the company. *Six Figure Club membership is NOT a lifetime rank or title and must be continually achieved for continual participation and promotion.
Each of these distributors has earned at least $1000.00 in total monthly commissions, at least 2 months consecutively.
Members of the Grand A Month Club will be promoted and recognized by the company and have the option, with approval from the company, to hold meetings and do presentations using company approved materials. Anovite will assist in aspects of event planning based on each event individually.
Interested in becoming a wholesale customer or an Anovite business partner? Start here!


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Client Testimonials
We have worked with Charmayne to buy two houses and sell two houses. She is very professional and always willing to help any way she can. She is a great pleasure to work with.- Vernon and Sheryl Gatliff
Fantastic Selling Experience!
I had a challenge on my hands. My father lived in Kingman, AZ and I live in Nebraska, and I needed to sell his home. I reached out to Charmayne Keith for help. The process from that point on could not have been more positive or smooth. As you might expect, not being physically in the same town, or state for that matter, posed some challenges. The first was signing all the necessary documents. Charmayne was able to provide a document portal and tool that essentially walked me through and e-signed each area requiring a signature. It couldn't have been easier! The next challenge was getting the house and carpets cleaned. I had no idea who to reach out to or how I would get them access to the home. Again, Charmayne stepped up and went above and beyond. She worked with reputable third-party individuals, coordinated the access they needed and ensured they did a good job.
Charmayne was able to secure competing bids on the home within a very short period of time. She again did a great job coordinating the offer signing as well as the inspection and follow-up processes. She took the time to personally reach out during each step and make sure I did not have any questions. I am not sure what I would have done without her help! Charmayne is professional, and just as important, personable. I only wish she was licensed in Nebraska to help me sell my home if the time ever comes!
Charmayne! We wanted to take a minute to let you know how greatful we are for all the time and hard work you put in to, not only selling our house, but going above and beyond helping us through the whole process. Not only did we have our offer within two days, it was full cash asking price!!! We are so glad to have worked with you again and would strongly recommend you to anybody looking to buy or sell, your experience and care have made this process so very quick, easy, and seamless, it is still amazing to us! Thank you so much!- John and Tiffany Ryals.


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Antibiotic prescription and prevalence rate in the outpatient paediatric population: analysis of surveys published during 2000-2005.
Eur J Clin Pharmacol. 2007 Sep 21
Rossignoli A, Clavenna A, Bonati M.
Laboratory for Mother and Child Health, Mario Negri Institute for Pharmacological Research, via G. La Masa 19, 20156, Milan, Italy, firstname.lastname@example.com.
OBJECTIVE: To evaluate antibiotic paediatric consumption data in the community setting using data from studies published between 2000 and 2005 and to compare inter- and intra-country antibiotic prescribing patterns.
METHODS: A literature search was performed in EMBASE and MEDLINE to identify pharmacoepidemiological studies published between 2000 and 2005.
RESULTS: Large differences between studies were found, with significant heterogeneity in epidemiological indicators. Only 20 studies reporting comparable drug prescription data were considered in the analysis, all of which were from the USA, Canada, North-Central Europe and Italy. Pre-school children were reported as comprising the most exposed age group to antibiotic therapy (prevalence 72%; prescription rate 2.2 prescriptions/person per year). In the overall child and adolescent population (less or equal to 19 years), prevalence varied from 14 to 57% (mean 34%), and the prescription rate from 0.2 to 1.3 prescriptions/person per year. Relevant inter-country qualitative and quantitative differences in antibiotic prescribing were apparent, although these were observed in only a few countries: prevalence was higher in Italy and Canada (prevalence range 42-57%) and lower in the Netherlands and the United Kingdom (prevalence range 14-21%). Penicillins were the most prescribed antibiotics in all cases (40-70% of antibiotic prescriptions), followed by macrolides (16-45%), while cephalosporins accounted for a large proportion of the prescriptions in Italy (30-40%) and Canada, but were practically absent in North European prescriptions.
CONCLUSION: Comparative drug utilisation studies on antibiotic use in children are needed, as are improvements in regulatory and educational programmes aimed at limiting the number prescriptions given for antibiotics. Both approaches would address public health problems, such as bacterial resistance and safety and elevated costs, related to the use and misuse of these drugs.
PMID: 17891535 [PubMed - as supplied by publisher]


text: Hello! Lydia Jane Photography is going to undergo a lot of changes in the new year. Let's just say it's my one and only New Years Resolution at this point. :) With this in mind I have also decided to increase my prices. This is standard for photographers growing in their field and it's something I haven't done since my business started. For all those currently booked for a wedding or photo shoot in 2009, this doesn't change anything for you at all. For all my future clients, book your wedding, family photo shoot, senior photos, etc. before January 1st to receive the old prices!


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John McCain emerged from Super Tuesday the undisputed heavyweight in the fight for the Republican presidential nomination. He also flashed signs of a glass jaw.
McCain's apparent victories in eight states including the delegate treasure troves of California, New York and Missouri gave the perennial underdog a novel air of inevitability. But the wins don't appear to be enough to knock Mitt Romney nor the surprisingly resurgent Mike Huckabee out of the race quite yet. More worrisome is that McCain's soft vote tallies in southern states and the Bible Belt, as well as in exit poll results of conservatives across the country, exposed a profound weakness with the party's base.
Neither the victories nor their deficiencies took the McCain campaign by surprise Tuesday night. McCain spent the run-up to the nearly-national primary responding to blistering attacks from iconic conservatives such as Rush Limbaugh, James Dobson and Sean Hannity. While all three talk for a living and their antipathy for McCain is an old saw the impact of their comments was undeniable; even in his home state of Arizona, McCain lost self-described conservatives to Mitt Romney 47%-36%. "Is it a problem when you're getting the crap kicked out of you on talk radio and Fox [News] all day long? You bet it is," confided a McCain adviser Tuesday. "We're dealing with it. And we're winning in spite of it. And it will get better once we've got this [nomination] sewn up."
An outreach program to skeptical Republicans was kick-started before Super Tuesday, as the campaign gathered endorsements from high-profile conservatives like Senator Tom Coburn of Oklahoma; Ted Olson, the former Solicitor General who argued Bush v. Gore successfully before the Supreme Court; Jack Kemp; and former Texas Senator Phil Gramm.
But the real test of the gulf between McCain and conservatives and his ability to bridge it comes Thursday at the annual Conservative Political Action Committee (CPAC) conference in Washington. CPAC is the Lollapalooza of the Republican right, and its founder, David Keene, has been an outspoken critic of McCain's perceived anti-conservative transgressions on issues ranging from campaign finance reform (McCain's for it) to gun control (for it, in certain instances) to global warming (against it). As a result, McCain has routinely skipped the event; last year, he was booed in absentia. "He won't get a poor reception at CPAC; he'll get a mixed reception," says McCain adviser Charlie Black, who promises that McCain's conservative endorsements will be showcased at the event. "The conservative movement is a very broad group... I've been booed over the years." But, he added, "anybody who speaks [at CPAC], including Senator McCain, will get majority support."
Black suggested that even two of McCain's fiercest critics and by far the ones with the loudest megaphones would, if not fall in line, rethink their attacks on McCain if he locks up the G.O.P. nomination. "Sean Hannity and Rush Limbaugh will not be supporting the Democratic nominee against John McCain," Black said. For any nominee hoping to win in November, the goal for a general election is to receive 90% support from Republicans, a small slice of Democrats and a majority of independents. "Within a few weeks," Black predicted, "McCain will have 90% support."
Regardless of whether overwhelming conservative support comes, McCain can already feel the effects of being a bona fide front-runner. The campaign raised $7 million in January, including $1 million the first day after the Florida win. The campaign itself has also grown exponentially, from the 20-30 people (including press) who were traveling regularly with the Senator early in the month to the approximately 95 who piled onto the chartered Jet Blue Airbus 320 that flew the whole show from Newark to San Diego and finally to Phoenix on Super Tuesday. After a crowded, chaotic press conference featuring Rudy Giuliani and former New York Governor George Pataki in New York's Grand Central Station Monday afternoon a press conference at which McCain took just three questions Mark Salter, the candidate's close adviser and speechwriter, shook his head. "We're not used to being this big," he said with a scowl as he looked at his watch. "We've been late all day. We're never late!"
On the stump, McCain delivered a set-piece speech that wove his promise to defeat "the transcendent challenge of our time radical Islamic extremism," with chestnuts aimed at proving he would be an able and conservative steward of the economy. At one stop he led with a promise to "make President Bush's tax cuts permanent," an odd choice given that McCain famously infuriated conservatives by voting against Bush's tax cuts in 2001 and 2003. In his presidential campaign, McCain has said he supports making the cuts permanent because allowing them to sunset would have the effect of raising taxes, which would be both unpopular and potentially damaging to a weak economy.
But McCain's problems with conservatives probably can't be solved with high-profile endorsements or promises to cut taxes. For many, it will be enough if he wins the nomination and promises to do the right thing on the war, judges, taxes and spending. For others, it will take longer. Maybe forever. As Charlie Black said, "You might never get everybody." But to win, you just need 50.1%.


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Celebrity Voiceovers
Now, we don't like to brag, but we have been known to rub shoulders with a few celebs – Gabby Logan and Tony Robinson have lent their dulcet tones to some of our previous videos.
And a handful of ex-frontbenchers have also made cameo appearances … not necessarily at their request … but it was funn … ahem.
The point is, celebrity endorsement can add weight to your message.
Most recently, we had the pleasure of welcoming Olympian - and genuinely lovely chap - Tim Foster, into the studio to record a voice over for the British Pharmacological Society's latest animation warning 10-14 year olds about the dangers of drugs and supplements.
Elsewhere, we've created an animation for the Portman Group that brings together a range of official statistics to reveal drinking trends in the UK, an animation for the Institute of Alcohol Studies highlighting the problem of cheap, high strength alcohol, and we've been reinventing stock footagewith animated overlays to highlight the success of offshore wind for Renewable UK's campaign during Offshore Wind Week.
We also completed our first company results animation for a FTSE 100 company. The obvious challenge with a project like this is the hard deadline. But we're used to those!
So the real challenge here was managing a project where the underlying information is subject to change right up until the very last minute. The combination of cool heads, communicative clients and our usual collaborative approach won out.
Looking ahead to December, we have a rush of projects with Christmas deadlines and a few festive surprises in store – speaking of which, it's probably time for the Production elves to get back to the workshop!


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The general practice at Wilbury Road has been in existence for many years. Initially situated in The Drive, the practice relocated to 28 Wilbury Road some 20 years ago. On the 1st of February 2013 we moved to number 40 to join Wilbury Physio. We hope to expand the practice and offer many more services over the coming months.
Dr Duncan Stewart originally ran the practice and continued to do so until his retirement in 2010. Since that time Dr Stephen Parish has taken over the practice.
Dr Parish believes that private general practice offers time and flexibility allowing him to give a thorough and highly personal service to his patients. Prior to coming to Wilbury Road, he has over 25 years of experience in the NHS.


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We have a client, let's call him David to spare his blushes.
David is an expert in his field, he's a professor and someone who's invited to speak on his area of specialism around the world but he's a modest chap, and despite these regular invitations, he still questioned why he's feted in this way and wasn't sure that he was interesting or knowledgeable enough to be featured in trade titles.
Before we started work with him a few years ago, he'd never really done any PR. He'd published some papers and was known within his field to a certain extent but he'd never really pushed himself forward and was nervous about the prospect of undertaking PR activity.
Since we've been working together, we've generated commissioned articles for him in the trade media relating to his industry and he now has regular columns in several titles and is well known in the industry.
The results have been impressive. Just recently he attended a conference as a speaker, along with some top level executives from some of the leading companies in the UK and around the world. Being so unassuming, he was wondering why he'd been invited up to share a platform with these people who front such well-known companies.
He assumed he was there to just make up the numbers and that the questions would all be aimed at his fellow panellists. It soon became clear however, that he was the one that all the delegates aimed questions at and wanted to speak to after the conference.
The reason?
Because he had proved that he really knew his stuff. Through commissioned articles and by posting the articles on social media he generated comment and interest and consolidated his position as the leading expert in his field.
He was already highly regarded but by working with him to understand his company, his key messages, his target audience and pitching good story ideas, we were able to generate the press coverage to position him as a thought leader.
His workload has increased and he's in more demand than ever before. Everyone in his industry knows who he is, his clients know that they're in safe hands and his competition are wondering why he's now in this position.
If you're considering embarking on PR but are worried that you don't know enough and aren't experienced enough, remember, you know more than you think you do. If you're not promoting yourself, your competition will be promoting themselves and once they become the go-to experts in their field, it'll be difficult for you to catch up.


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What Touches the Heart?
Sometimes the heart sees what is invisible to the eye.— H. Jackson Brown Jr.
What do you feel when you look at this picture?
Feel With Your Heart
Many say we feel things because we think them, but I disagree. I think we feel with our hearts. We really aren't responsible for what we feel. We can change what we think, how we act, what we do, but we really can't change how we feel. Our feelings are just there without any conscious effort, sometimes even when we don't want them to be!
Deep within our hearts lie all of our feelings. Our mind does the thinking and our heart does the feeling. With that feeling our heart gives us an energy of love. We have to learn to go with what has been termed our "gut feeling", but what it really is, is our heart trying to talk to us. Our heart sees no evil, sees no bad in people. We are inherently good and filled with love. It is time and the outside world that can change the love in our hearts.
Have you ever meditated? Did you feel relaxed and feel the love in your heart? Whether it is called meditation or prayer, a time alone to be thankful will certainly help your feelings of love. Try it, those feelings are always there waiting for you to feel them.
The best and most beautiful things in the world cannot be seen or even touched - they must be felt with the heart.— Helen Keller
Feel the love?
Open Your Heart
Of course we all think our hearts are open, but are they? Have we closed our hearts for some reason? We think we let our hearts guide us through life, but do we? Take a look at this list and see if you can find yourself there.
11 signs that your heart is open.
- You have a song in your heart.
- You smile and laugh easily.
- You show affection towards others.
- You love to hug.
- You see the good in people.
- You ignore the "bad" in people.
- You are open to new experiences.
- You accept people just the way they are.
- You show interest in others.
- You are in love with life.
- You attract awesome situations and events into your life.
(The 11 signs was taken from http://www.thevortex.me/opening-of-the-heart/ )
What better way to live than with an open heart? Your heart may sometimes close because of sadness or hurt, but you can't let it stay that way. If you do you will become bitter and start to withdraw from life. You need to keep your heart open and be in love with life. You don't have to go around telling everyone that, just live it.
There are programs and articles all over the Internet on how to open your heart, but the easiest most positive way to open your heart is to let it feel. Feel what is around you. Feel the love of family, feel the life in the world, or start small with your garden or a tree in your yard. Feel the love of a pet, so unconditional and always there for you. Feel the life. Use that meditation to feel the love in your life, from family and friends, from pets. Smile while you are meditating to let the good thoughts and feelings fill you. Sometimes a smile leads a path to your heart.
Be thankful for the small things. Be happy you woke up this morning, be happy you have a roof over your heard, be happy you are able to read this. Find the happiness and your heart will open.
Sometimes the smallest act of love can take up the biggest space in someone's heart.— Unknown
The Service of Others Can Open Our Hearts
What Touches Your Heart?
Are you touched by those cutesy youtube videos? You know the ones with the little puppies or other baby animals. What about the ones showing an orangutan taking care of a baby kitten or the Budweiser ones where the dog and the horse find a bond? Do the uplifting videos make you smile or cry? Videos like the ones showing a father coming home from a tour of duty and surprising his children at school.
Are you touched by the pain and suffering of others? Touched enough to want to do something to try to make it better or at least ease the pain you see? Maybe it's just a small donation, but at least it is something.
How do you feel when you see a mother holding her newborn? Does a baby touch your heart? I could go on asking questions till the cows come home, but it is you who has to ask the questions. You need to know what touches your heart and how you can open your heart to the love you were born with.
I remember the first time I heard the saying, "He ain't heavy, he's my brother." That touched my heart deeply. Of course the movie about Boys Town touched my heart as well. The generosity and unselfishness of Father Flannigan was a joy to see, but better still to know it was real, that it happened. It can happen anywhere, anytime and it does every day if we just look for it and keep our eyes and hearts open.
Prayer can touch some hearts and bring them back to the purity they once knew. We were born with pure and loving hearts, tainted by others as we grew up. Some hearts are touched by the generosity or kindness of other people. Sometimes it's something as simple as holding the door open for someone, or picking up something they didn't know they dropped.
The touch of a newly opened flower or a butterfly's wings softly flitting against your face. There is so much beauty in the world not only to see, but to touch your heart if you just let it.
Falling in love touches your heart, but staying in love can fulfill it. The warmth and joy you feel when the person you love loves you back can't be made up or imagined. Even if your love isn't returned, it is free to give and giving it will touch your heart.
Will You Open Your Heart?
I hope reading this has touched your heart. Touched your heart and opened it to the wonders around you. If just one person feels a new love or awareness from this, then I have spread the love. That is what I wanted to do, touch your heart and spread your love.
Open your heart and let the sun shine in to brighten your day and your life. Let the sun clear away the clouds that hide the beauty of you and your heart. Forget the bitterness in the world and concentrate on the goodness. It is sometimes difficult to see, but it is there. Strangers helping strangers, people giving of themselves expecting nothing in return. Where this is life there is hope and where there is hope, there is love. Why not look for the good in people and try to see the love they share everyday. Start your day with a song in your heart, open your heart and live the love.
Copyright Tillsontitan - All Rights Reserved
Interesting Mary--I think for me there is a difference between joy and an open heart. I think of an open heart as having the courage to keep feeling all the feelings we have even the ones that are hard or painful. So for me, I am touched by that kind of courage most
This hub touched my heart as does your friendship. Your words reminded me of a quote that I recently read and could totally relate to...
I'm proud of my heart. It's been burned, broken, stabbed, played and burned, but somehow it still works. (Something like that.) Anyway you get the point :)
Nature is beautiful. I enjoy spending time in my environment. A greatly written hub.
Every day, nature makes me feel exactly like this. For me, it is truly what makes me tick.
Great write and definitely touched my heart. Positive and inspirational, enjoyed reading.
Mary, I have bookmarked this inspirational hub, to return and read, again and again, for they resonate with the true meaning of love...and the miracle of humanity. These are words not only to live by; but to carry close to our hearts, each and every day.
This is pretty poignant for me, I am trying desperately to forgive someone but its hard, so this really helped, I am a stubborn fool sometimes! lol!
Dear Mary,
I appreciated learning the 11 signs of an open heart...as well as the passion you put into the ponderings of this post.
Beautiful work. Love, Maria
What an interesting message. You put a lot of thought into this and that is apparent.
This was lovely and inspiring, Mary, and I have saved it for reference. If I begin to feel that the laugh in my heart and the smile in my eyes needs replenishing, this is where I will turn. Promise!
Til, what a warm and heart touching hub... I bet if anyone feels stalled this hub will stir them back up and motivate them to really feel whats in their hearts bravo :)
Beautifully stated. Wonderful read!
I think the big problems in life is when our mind tries to override our hearts; we should always listen to our heart....and then follow with a big HUG!
Dear Mary,
Thank you for sharing these wonderful insights about the tremendous power of our hearts to feel love and then be able to love life and love all others. I think the most beautiful people on this planet are those whose hearts are beautiful ...by that I mean that a person can be physically beautiful on the outside to the world, but if their heart is not, then sadly their inner beauty has been squelched by something in this life. Be that as it may, the heart is resilient and can feel love again.
I am reminded of what God tells us in His Word that "From out of the mouth, the heart speaks." Which to me means that we can tell so much about the condition of our and that of another's heart from the words that are coming out of the mouth.
Prayer helps me to get my heart right when I am out of sorts.
Peace and love always
Sharing this lovely message everywhere
The world would be a better place if we all quieted our minds and let our hearts speak for us.
Great article, Mary!
What a beautiful Hub, Mary. Very necessary in this life. The thing we need most and sometimes turn away from.
I note your 'appeal' as a clarion-call to use the Heart. The Heart is the Seat of Life and all else flows from this ever-eternal Source. Hari Om!
I am a cliche lover myself, Til......Let's consider Ghandi "Be the change you want to see in the world."......Powerful.
Beautiful hub! The heart must be opened to all things of life. To allow oneself to explore with an open heart is key to feeling the experience. I like this hub.
Awesome message. My heart always opens up whenever I read or view such nice things and a wave of blissful current runs throughout my body. Thanks, Mary, for sharing this wonderful hub.
Just a wonderful topic, Mary, and you handled it perfectly. One might say you touched my heart with this excellent article. An open heart? All of us? As John Lennon would say, just imagine what that would be like.
Thi is a beautiful message Mary. I certainly believe that we feel with our heart and it doesn't always match up with what our mind tells us we should be doing. I like those 11 signs your heart is open, and thankfully I could tick most of those boxes. Everyone needs to read this. Well done.
Had to re-read Mary and I got one answer for you: "How do you feel when you see a mother holding her newborn? Does a baby touch your heart?"
It gives me tears of Joy emanating from my heart.
Sometimes it is easier said than done specially if you've been hurt in the past. But yah, past is past...let's move on and open our hearts (again).
Happy to have landed in this hub and to spread some love from the sky. :)
A wonderful message. Matters of the heart are special.
Sweet, Mary. And I have noticed in the past when I was really hurt emotionally I could feel it in my chest!
Mary, you old romantic you! (not old old, you know what I mean). I have a new love and I'll go for all this!
Powerful & Inspirational, GF. Something very much needed in this world of ours, more & more each day. As we know, it begins with "us." One person, one act of kindness, one word of love.....one day at a time. The speed at which this can spread throughout is simply amazing!
Peace, Paula