Compliance Alert: EEO-1 Reporting Update

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Employers and HR Pros finally have an update regarding the Equal Employment Opportunity (EEO) Survey. The pay and hours update (aka Component 2) to the EEO-1 Survey has been long-anticipated. Employers are relieved to learn the pay data and hours collection requirement has been pushed to September 30, 2019. Component 1, however (which is the current EEO-1 report) is still due for applicable employers on May 31.

Here's what you need to know about EEO Reporting in general: The Equal Employment Opportunity Commission (EEOC) is a federal agency that administers and enforces workplace discrimination laws and collects race, ethnicity, and gender data by job category from applicable employers via the annual EEO-1 Survey. Employers with at least 100 employees, as well as federal contractors with 50 employees and a contract, subcontract, or purchase order of $50,000 or more, are required to submit the EEO-1 Survey annually. Noncompliance or false statements can result in severe penalties.

The current EEO-1 report is available in the CheckWriters platform to aid in submitting the survey to the EEOC for the regular May 31 deadline. However, HR Platforms do not yet have component 2 spec details to deploy in their systems for the additional and upcoming Sept 30 deadline. The EEOC has promised to make the survey submission portal available to applicable employers by mid-July, and to provide information and training to employers in advance of this timeframe.

It is advisable for employers to start looking at their data now and conduct an initial assessment of their systems and workforce composition with pay and hours detail in the mix. Both 2017 and 2018 pay and hours data will need to be reported by September 30, 2019. This will require employers to report wage information from Box 1 of the W-2 form and total hours worked for all employees by race, ethnicity, and sex within 12 proposed pay bands (the pay bands have not yet been provided by the EEOC). The reported hours worked should show actual hours worked by nonexempt employees, and an estimated 20 hours per week for part-time exempt employees and 40 hours per week for full-time exempt employees.

It's unsurprising these changes have materialized, particularly with the recent emphasis on pay equity and transparency. However, it will be challenging to ensure data completion and compliance with these additions and the more granular detail now required in the survey.

If you haven’t yet performed a compensation and pay practice audit (perhaps paired with a diversity and inclusion review), now is the time! The CheckWriters platform as well as our HR team is here to help you with your questions and needs surrounding EEO compliance, equitable compensation management and planning, and other imperative areas of compliance and policy review.

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