NT Lakis lawyers submitted comprehensive written comments this week to the White House Office of Management and Budget (OMB) in response to the Equal Employment Opportunity Commission’s (EEOC) controversial proposal to revise the Employer Information (EEO-1) Report to collect summary compensation data from covered employers.

Our letter, which complements the points we raised in written comments submitted on the EEOC’s original proposal earlier this year, as well as testimony we presented on the proposal at a public meeting held by the EEOC, details the proposal’s serious flaws, including the substantial reporting burdens that employers would bear in providing data we believe will be of little or no use to the EEOC in actually identifying pay discrimination.

Pursuant to the federal Paperwork Reduction Act (PRA), OMB must approve the EEOC’s proposal before it can go into effect.  The PRA also authorizes OMB to reject the proposal and send it back to the EEOC for revisions, which is what we are urging in our comments to OMB.

Members of the Equal Employment Advisory Council (EEAC) can read more here.