by Laura Pokrzywa
Since 1966, most employers with federal contracts or with 100 or more employees have been required to report the number of workers they have in specific job categories, breaking the numbers down by ethnicity, race and sex. These statistics have been reported to the U.S. Equal Employment Opportunity Commission (EEOC) as part of the annual Employer Information Reports (EEO-1) filed by covered employers. The EEOC then provides data collected via the EEO-1 reports to the Office of Federal Contract Compliance Programs (OFCCP) at the Department of Labor.
If you can answer yes to any of the following questions, your company is required to submit and certify an EEO-1 report no later than September 30, 2016:
- Does the entire company have at least 100 employees in the payroll period for which you are reporting?
- Is your company affiliated through common ownership and/or centralized management with other entities in an enterprise with a total employment of 100 or more?
- Does the company or any of its establishments (a) have 50 or more employees AND (b) is not exempt as provided by 41 CFR 60-1.5, AND either (1) is a prime government contractor or first-tier subcontractor, and has a contract, subcontract, or purchase order amounting to $50,000 or more, or (2) serves as a depository of Government funds in any amount or is a financial institution which is an issuing and paying agent for U.S. Savings Bonds and Savings Notes?
If you are required to file and haven’t done so yet, the best method would be to use the web-based filing system. For more information and directions, visit the website of the U.S. Equal Employment Opportunity Commission (EEOC) by clicking on the highlighted text.
Be ready to add more details in next year’s report. Earlier this year, the EEOC proposed a change to the EEO-1 that would require covered employers to include the number of hours worked and W-2 earnings for each employee, as well. In a fact sheet that details the proposed changes, the EEOC says, “The pay data would help EEOC and OFCCP improve enforcement of federal pay discrimination laws. It also would promote voluntary compliance with the law and help employers avoid enforcement actions.”
When first proposed, the new EEO-1 reports with pay data were to be due Sept. 30, 2017; however, in July the EEOC published a revised proposal extending the report date for 2017 employment information to March 31, 2018. This revision came after comments from the public encouraged the EEOC to simplify employer reporting by allowing employers to use existing W-2 pay reports, which are calculated based on the calendar year. We will continue to watch for the final rule and keep you updated via our blog.
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If you have questions about EEO-1 reporting or any other HR issue, send us an email at HRhelpline@eastcoastrm.com.
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