While language from ISS indicates that its higher level of scrutiny will generally apply to companies that have received medium or high concern ratings on its quantitative pay screen, it's possible companies that receive a low concern could also be scrutinized if they run afoul of one or more of ISS' "egregious" compensation practices, such as excessive perquisites, gross-ups and severance paid without a termination without cause, among others, wrote Mike Kesner, partner at Pay Governance, in an email statement.

Meanwhile, although ISS' stated criteria for evaluating the design and disclosure of performance-based equity programs appear not to have materially changed on paper, ISS has made it clear there will be a heightened level of scrutiny for the subset of companies that it identifies as having a quantitative CEO pay-for-performance disconnect, Linda Pappas, principal at Pay Governance, told Agenda in an email statement.

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