National Association of Government Contractors

Contractors Prepare for Improved EEO-1 Reports

In years past, July has meant preparation for the annual EEO-1 Report filing for many contractors and employers. Until this year, covered employers were required to file their reports no later than September 30, and the data submitted had to be from any pay period in July, August, or September.

In 2016, the Equal Employment Opportunity Commission announced changes to the EEO-1 Report. As a result, there is no EEO-1 Report filing deadline in 2017.

However, as employers, many must file "new and improved" EEO-1 Reports by March 31, 2018, with compensation information for 2017. The new reporting requirements mandate that covered employers provide information on total compensation and total hours worked by race, ethnicity, gender, EEO-1 category, and designated salary bands.

The revised EEO-1 Report requires that employers provide substantially more information to the government, and this additional information is intended to assist the government in identifying employers committing pay discrimination.

In addition to attention to compliance by all employers, federal contractors are being recommended to take additional steps to reduce chances of receiving a Commissioner’s charge, or being selected for a compliance review by the Office of Federal Contract Compliance Programs. So, any reprieve in the filing deadline is offset by a need to ensure proper preparation.

Contractors are advised to:

  • Examine your EEO-1 categories. Are all job titles appropriately classified? You don’t want your data unnecessarily skewed because you are including employees in the wrong groups. As job duties change over time, so too may the proper EEO-1 category.
  • Conduct a privileged compensation analysis. Have you determined whether pay differences are explained by legitimate factors such as seniority, time in job, etc.? If not, it would be wise to find them and make any necessary corrections before the data is set at the end of 2017.
  • Consider performing a practice run at completing the report before the deadline of March 31, 2018. This would allow you to discover potential complications or problems with your internal data and reporting process. Preparing a draft report would also provide an opportunity to see how the data may be viewed by the government. For example, are the top salary bands in each EEO-1 category comprised of white males, or is there good distribution among the races and genders throughout each EEO-1 category?

Federal contractors should not delay preparation to comply with the new reporting requirements. Because of the volume and nature of information being requested,  you are urged to not wait until the last minute to consider these issues and develop an action plan for compliance.

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