Last fall, the Equal Employment Opportunity Commission (EEOC) received approval from the outgoing Obama Administration’s Office of Management and Budget (OMB) to immediately begin using an expanded EEO-1 Report that added billions of new data points regarding employee pay and hours worked to the data covered employers were already required to collect and report annually.
The EEOC also announced that the expanded reports would be required for the 2017 filing season, but that completed EEO-1s would not be due to the agency until March 31, 2018, rather than September 30 of this year, the traditional filing deadline for the old EEO-1.
The new EEO-1 has prompted strong objections from covered employer representatives, who claim that the expansive additional data to be collected is unlikely to meaningfully help identify unlawful or improper pay practices, that the data would be extremely burdensome to report and collect, and that the EEOC has failed to adequately address important confidentiality concerns. In fact, these concerns have been communicated to both the EEOC and the Trump Administration’s OMB, with a request that OMB reconsider its prior approval of the new form.
Although we believe that there is a real possibility that OMB might still reconsider its approval of the revised EEO-1, the fact remains that as of this writing, covered employers will be required to begin filing the expanded EEO-1 by the end of March of next year. Accordingly, NT Lakis staff has prepared a guide to issues that employers might want to consider now in preparing for the possibility of having to comply with the new two-step data collection process that will be required under the revised EEO-1’s expanded data collection and reporting requirements.
Members of the Equal Employment Advisory Council (EEAC) can read more here.