The U.S. District Court for DC ruled March 4 that the EEOC must reinstate collection of Component 2 EEO-1 pay data immediately, which may require employers with 100 or more employees to submit reports of their workersâ€™ wages and hours, broken down by race, gender and ethnicity, to the EEOC, retroactive to January 2018.
NPRC members suggested that a letter to EEOC may be helpful, to explain the difficulty in retroactive reporting, even for 2019, which would involve a largely manual effort to gather â€œhoursâ€ data for salaried and other workers that may not have accurate hours. Additionally, technical specifications have not been finalized to collect the Component 2 EEO-1 pay data. Employers and software developers need at least 6 â€“ 9 months to design, develop, test and deploy programming to support any new reporting.
NPRC is strictly neutral as to the appropriateness or need for proposed changes to the EEO-1 annual report. However, we serve in part to offer constructive technical assistance to government policymakers concerning proposals that affect employment-related reporting.
We suggested a meeting with the Commission and other stakeholders to assess the earliest readiness of employers and the EEOC to execute the Component 2 reporting.