UPDATE!: EEO-1 Pay Data Reporting

UPDATE!: EEO-1 Pay Data Reporting

Last month, we informed our clients and colleagues of the recent, pending decision of whether or not qualifying employers would be required to submit Component 2 (collection of pay data) of the EEO-1 report by May 31, 2019 in addition to Component 1. “Component 2” of the EEO-1 report is intended to analyze pay data to determine any disparities or discrimination in pay, with the goal of improving upon this issue should any discrepancies come to light.  

Last week, the EEOC finally released an update on the requirement to submit pay data. Employers who meet the EEOC’s reporting criteria are required to submit Component 2 of the EEO-1 report for both 2018 and 2017 no later than September 30, 2019.

Note: Employers are still expected to submit Component 1 of the EEO-report by the May 31, 2019 deadline.

The EEOC will begin accepting this component of the report in mid-July from employers who file the EEO-1 report annually who have more than 100 employees (in both the private sector and some federal/government contractors or subcontractors with more than 50 employees). Employers are expected to report pay data which includes hours actually worked and pay data gathered from their employee’s W-2 forms which will be categorized by race, ethnicity, and sex.

2019 EEO-1 Reporting Deadlines:

  • May 31, 2019:  Component 1 data for 2018 is due
  • June 14, 2019: Component 1 data for employers that requested a two-week extension is due
  • July 15, 2019: Expected date employers can begin submitting Component 2 of the EEO-1 report
  • September 30, 2019: Component 2 data for 2017 and 2018 is due

Don’t wait until the last minute to get this data compiled; HRCentral is here to help you and your HR Department gather and submit data for your organization’s EEO-1 report. Contact us today for assistance in filing or for establishing a streamlined reporting process.

EEO-1 Pay Data Reporting

EEO-1 Pay Data Reporting

In 2010, the EEOC ordered a study in an attempt to determine various ways to improve the prohibition of pay discrimination and determined that there would be great value in analyzing pay data should that information be submitted with standard EEO-1 reports. This study needed approval, and in 2016 the Office of Management and Budget approved this collection of data which would require employers subject to EEO-1 reporting requirements to submit pay data in addition to the standard information on race/ethnicity, gender, and job category. This collection of pay data (known as “Component 2” of the EEO-1 report) was delayed in August of 2017 and in March of 2019, this postponement was lifted.

After years of going back and forth on whether or not there would be a mandatory requirement to report pay data, on April 3, 2019, the EEOC informed the federal government that its current data collection processes were not capable of collecting the required pay information for the Component 2 of the EEO-1 report. Rather, they would have to rely on outside contractors and analytics to gather and review salary information. With the deadline to submit this information of May 31 looming, concerns were raised as to the quality of the gathered data with the short amount of time to collect salary information.

As a result of so many unanswered questions, it is still undetermined if eligible employers will be required to submit Component 2 of the EEO-1 report by May 31, 2019. In the meantime, employers are still expected to submit Component 1 of the EEO-report by this deadline.

While the requirement for salary reporting is still pending, employers are encouraged to start preparations for this change to the reporting process. HRCentral suggests that you create a simple spreadsheet of your current employee’s salaries, including any new hires or terminated employees, similar to what you use for reporting Component 1 of the EEO-1 report.

Don’t wait until the last minute to get this data compiled; HRCentral is here to help you and your HR Department gather and submit data for your organization’s EEO-1 report. Contact us today for assistance in filing or for establishing a streamlined reporting process.