The long-anticipated announcement from the EEOC regarding the future of EEO-1 reporting requirements has been posted. The EEO-1 report is utilized by both the EEOC and OFCCP (Joint Reporting Committee).
For example, the report is used in assisting the OFCCP in selecting covered contractors for compliance reviews. These reports which are required to be submitted annually and contains information regarding the contractor’s industry, county, location, and race/ethnicity and sex information of the organization’s workforce by EEO-1 classification.
Federal contractors and covered subcontractors have been anxiously awaiting news regarding whether they would be required to also submit pay data and hours worked, in addition to existing requirements as part of revised EEO-1 reporting requirements.
On August 29, 2017, the Equal Employment Opportunity Commission (EEOC) posted an update on the status of the EEO-1 report. Based on yesterday’s announcement from the EEOC, there will be a “review and immediate stay of the effectiveness of the pay data collection aspects of the EEO-1 form that was revised on September 29, 2016.”
Based on the EEOC announcement, for the time being, employers will not be required to also submit information regarding pay data or hours worked on their EEO-1 reporting. The previously approved EEO-1 form will be utilized which only collects data on race, ethnicity, and gender by EEO-1 classification.
Note that the submission of EEO-1 forms is not applicable to state and local governments, public primary and secondary school systems, institutions of higher education, American Indian or Alaska Native tribes and tax-exempt private membership clubs other than labor organizations.
The filing date for the next EEO-1 submission will remain March 31, 2018.
It’s important to keep in mind when preparing for the next EEO-1 reporting that you set your employee snapshot to cover the year-ending December 31, 2017. And while the reporting requirements do not change, start preparing now to be sure for a timely filing by March 31, 2018.
Also, we recommend in preparation that you perform statistical stress tests—statistical analysis that can be performed on your data to spot any areas of potential concern and also conduct a comprehensive pay equity study.
As a reminder, all applicable federal contractors must still file the VETS-4212 report by September 30, 2017.