Federal contractors are required to file two annual reports regarding the composition of their workforce: the Employer Information Report (EEO-1) and the VETS-4212. Both reports are based on employment data as of a single point in time, commonly referred to as a “snapshot.” Both have set rules defining the period from which that snapshot must be taken. Because the periods for the two forms have overlapped, in the past most contractors have elected to do a single data extract for both reporting requirements to reduce the overall burden.
Last year, however, the Equal Employment Opportunity Commission (EEOC) issued an expanded version of the EEO-1 and changed the snapshot period from the 3rd quarter of each year (July 1 – September 30) to the 4th quarter (October 1 – December 31), meaning that the snapshot periods for the two forms no longer overlap. This in turn has prompted some confusion among contractors regarding whether there is still a way they can synchronize the data extraction for the two forms.
The short answer is that yes, there will be a way going forward in which contractors will be able to synchronize the data extract for the two forms, although it might involve significant adjustments for companies that choose to do so. Accordingly, we prepared a guide outlining the options that will be available.
Please keep in mind that the following guide assumes that the White House Office of Management and Budget (OMB) will not reconsider its prior approval of the expanded EEO-1 form and its new filing deadline. There remains a possibility that OMB may do so, and if that occurs everything could change.
Members of the Center for Workplace Compliance (CWC) can read more here.