The 2017 reporting season for Employer Information (EEO-1) Reports is currently underway, and completed reports are due by March 31, 2018. Since the filing season opened, however, there has been some confusion created regarding how to report certain “remote” employees working at client sites, caused in part by new guidance issued by the Equal Employment Opportunity Commission (EEOC) and exacerbated by some inaccurate reporting by other organizations.
Bottom line, NT Lakis attorneys have confirmed with senior EEOC officials that employers still have the option of reporting employees who sit at client sites in either a report covering a company-controlled location (typically following the supervisory or human resources function chain), or a report covering the client address where the employee physically works. The determination as to which option to choose is the employer’s.
The 2017 electronic specifications, filing procedures, and the EEO-1 form itself are the same as they were in the 2016 filing cycle. Indeed, the only elements of the 2017 EEO-1 reporting process that have changed from last year are the allowable date ranges for the “snapshot” date that employers choose for reporting purposes, and the date that the reports are due.
Some confusion arose recently after new guidance materials posted on the EEO-1 Survey Website noted that employers with employees who work at client sites should file EEO-1 reports that cover such employees using corresponding client site addresses. The confusion was exacerbated by some groups erroneously reporting that this was now a mandatory requirement.
Members of the Center for Workplace Compliance (CWC) can read more here.