07 Sep EEO-1 Report
Private employers with more than 100 employees or certain federal contracts are required to complete an EEO-1 report each year by the end of September. Resource Alliance has already completed and submitted most of our client reports detailing the numbers of ethnicities and men/women in each job category.
The government has proposed a new format for the EEO-1 report that will greatly increase the administrative burden for employers. It is supposed to be approved this month and will expand the job categories, add more than 10 pay ranges for each job category, and include compensation information for each employee from that employee’s W2. If approved, an EEO-1 report will not be submitted in 2017. Instead, the report will be due by March 2018 based on the calendar year pay data for 2017.
The challenge with the proposed format is the use of W2 taxable wages as the measure for pay equity between sexes and ethnicities. Attorneys are predicting an onslaught of audits and questions from the Equal Employment Opportunity Commission, so employers will have to justify reasons for pay differences, for example, between a man and a women who have a similar job title. They will only see the taxable wages and won’t know that the man got a bonus, and that explains the difference between the two numbers.
Federal regulations are requiring more and more of employers, and Resource Alliance will continue to keep you informed. If the new format is approved, we will be prepared to answer questions in 2018.
Scott Mastley, SPHR, MBA, is the Chief Human Resources Officer for Resource Alliance.
Scott is a consultant, not an attorney, so he shares his opinions, not legal advice, about increasing performance and limiting liability.