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If you haven’t been paying attention to the EEO-1 pay data issue, please start now.

You have two EEO-1 filings to worry about this year. You already know that the standard EEO-1 race/gender report is due May 31, 2019, pushed back from its March filing date due to the recent government shutdown. It is the brand new, compensation-focused filing requirement that should be making you stand up and take notice. You have until September 30, 2019 to file this second EEO-1 “Component 2” report. The report will present W-2 pay data and hours worked detail by EEO-1 job category, pay band, gender and minority sub-group. This year you must report for both 2017 and 2018.

The pay data report has a long and tangled history. In 2017, after a contentious review period, the EEOC had second thoughts about the filing and “stayed” it (put in on hold). Court action by a civil rights group, the National Women’s Law Center, resulted in the requirement coming back in force this year. The Court set the September 30th filing deadline.

The EEOC originally planned to give companies 18-21 months to get ready for the pay data filing. Given Court intervention, we now have less than 5 months. The EEOC states that there is little likelihood that appeal or other legal action will delay this year’s filing requirement.

The EEOC will update soon with information on the new requirements. The Agency will open a help desk in a few weeks.

It will be hard work to organize pay and employee records into the required reports. So, do get to work on this, if you haven’t already.

With a new EEOC Chair just appointed, EEOC may well change the EEO-1 reporting requirement for future years. AJE will keep you updated as developments occur.

Read other articles in this series

In this article we welcome Paul McGovern, a compliance practitioner with a practiced eye. Paul is the founder of Praxis Compliance, an HR consulting firm focusing on Affirmative Action program implementation and audit response, D&I program analysis and remediation, and EEO/ER charge investigation and resolution. Former program lead for Verizon Communications Affirmative Action and EEO/ER investigations initiatives, responsible for the design and implementation of compliant HR processes company-wide, Paul led groups successfully responding to 180+ OFCCP audits and 2,000+ employee relations matters and agency-filed discrimination and harassment complaints. Paul is Chair of the National Industrial Liaison Group (NILG), a consortium of nation-wide Affirmative Action practice groups partnering with federal contractors and regulatory agencies to ensure equal opportunity.

Note: This article is meant to assist in a general understanding of the current law and practice relating to OFCCP. It is not to be regarded as legal advice. Companies or individuals with particular questions should seek advice of counsel.

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Roselle Rogers
Vice President, Diversity, Equity, and Inclusion
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Roselle Rogers, SPHR, SHRM-SCP, is the Vice President for Diversity, Equity, and Inclusion at Circa with responsibility for leading its DEI strategy and thought leadership initiatives. She is a subject matter expert in HR and OFCCP Compliance, affirmative action, EEO, and diversity; and frequently speaks on these topics at various HR conferences and webinars, educating and keeping federal contractors abreast of trends and recent developments in OFCCP/AA/EEO compliance. Prior to this role, Rogers was responsible for the company’s HR, compliance, business operations, and sales support operations, contractual and legal affairs, corporate training, and strategic initiatives. She has more than 30 years of HR experience and is certified as a Senior Professional in Human Resources (SPHR) and SHRM - Senior Certified Professional (SHRM-SCP). She is a member of the Milwaukee and Chicago chapters of the Industry Liaison Group (ILG), a presenter on the Circa OFCCP webinar series, is the lead editor of the weekly Circa publication, The OFCCP Digest, and an in-house expert on the online forum Ask the Experts. She served as a Director on the Metro Milwaukee SHRM Board, chaired the Metro Milwaukee SHRM Certification Committee, and facilitated the SHRM SPHR/PHR Certification program. Roselle is a graduate of the University of the Philippines with a Bachelor’s degree in Economics and a Postgraduate Diploma in Human Resources Development from the Ateneo de Manila University. She currently volunteers her time as the Vice President/Secretary of the Milwaukee Industry Liaison Group and President-elect of the University of the Philippines Alumni Association of Wisconsin.

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