In an article published by the Nashville Business Journal, Bass, Berry & Sims attorneys Bob Horton and Ginette Brown urge employers to get ready for the U.S. Equal Employment Opportunity Commission’s data reporting. Although facing criticism, the U.S. Equal Employment Opportunity Commission (EEOC) is moving forward with its pay data collection, and with the reporting deadline set for September 30, employers should prepare now.
Employers with more than 100 employees and any federal contractors with more with 50 employees are required to submit an EEO-1 survey, which has historically analyzed organizations’ employment data categorized by sex, race and ethnicity. Under the new reporting requirements, employers and federal contractors with more than 100 employees will also report compensation data. “Under the EEOC’s new pay data reporting requirement, employers and federal contractors with more than 100 employees will report compensation data by stating the number of employees within 10 specified job categories (executive/senior level officials and managers; first/mid-level officials and managers; professionals, etc.) and 12 pay bands ($19,239 and under; $19,240-$24,439; etc.) by gender and race or ethnicity for two groups of employees identified in a ‘snapshot’ of any pay period during October through December for 2017 and 2018,” Bob and Ginette explained. “Employers must also report the sum of all hours worked by all employees included in the number of employees identified in any ‘cell’ within the [EEOC’s] compensation matrix.”
“Employers should collect and review this data as quickly as possible,” added the authors. “While questions have certainly been raised as to the usefulness of the data with respect to being able to identify potential pay discrimination, employers will want to know well before the filing deadline whether the data being reported to the commission will suggest on its face the presence of any unlawful discrimination.”
The full article, “EEOC’s Pay Data Collection: What Employers Need to Know Right Now,” that contains more details on the new reporting requirements and procedures was published by the Nashville Business Journal on July 10, 2019, and is available online.