The Equal Employment Opportunity Commission (EEOC) has published for public comment a proposal to expand the annual EEO-1 Report to require all employers with 100 or more employees to report their establishment-level race/ethnicity and gender headcount by 12 new compensation bands within each of the existing 10 EEO-1 job categories. Placement of employee headcount figures in each pay band would be determined by the employee’s W-2 earnings, and covered employers also would be required to report the total number of hours worked by the employees reported in each of the 1,800 cells on the new proposed EEO-1 form.
The proposed EEO-1 changes, published in the Federal Register on February 1, 2016, would become effective for the 2017 EEO-1 reporting cycle. Based on our analysis, in terms of the number of data elements collected on the EEO-1 form, the EEOC’s proposal would increase the current reporting burden by over twenty-fold.
According to the EEOC, the revised proposed EEO-1 form will replace OFCCP’s proposed Equal Pay Report, and federal contractors will be relieved of a potential dual reporting obligation.
The EEOC’s proposal is technically an “Information Collection Request” (ICR) subject to federal Paperwork Reduction Act (PRA) requirements. The deadline for public comments on the EEOC’s proposal is April 1, 2016.
Copies of the proposed revised EEO-1 and additional information, including “fact sheets,” are available here.