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News & Press: EEO News

EEO-1 “Component 2” Pay Data Reporting Starting To Show Signs Of Life

Friday, April 26, 2019   (0 Comments)
Posted by: Matt Nusbaum
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As anyone responsible for EEO-1 reporting is well aware, the 2018 EEO-1 Survey is currently open and the 2018 reports are due by Friday, May 31, 2019. The 2018 reports were originally set to be due by March 31, 2019, but due to the government shutdown, the Equal Employment Opportunity Commission (EEOC) had to push back the opening of the filing season and accordingly extended the filing deadline.

Because of all the news, talk, and speculation about the EEO-1 lately, what might be less clear to some is what has to be reported by May 31. The answer is actually quite simple: it is the same EEO-1 report that you have been filing for years with the headcounts of employees at each reporting establishment broken-down by the ten familiar EEO-1 job categories. That’s it.

What about “Component 2,” the pay and hours worked reporting element approved at the end of the Obama administration, then rescinded at the start of the Trump administration? The Trump administration’s action has been successfully challenged in federal district court and the EEOC has been ordered to reinstate “Component 2” reporting for the 2018 EEO-1 filing season. Further, EEOC has committed to setting a September 30, 2019 deadline for the collection of this new component.

That may or may not be the last word with regard to Component 2. There is the possibility that the government will appeal the District Court’s decision. There could also be further legal challenges waiting in the wings. Either of these things could further delay the implementation of Component 2, or not. The prudent course of action would be to prepare to file Component 2 by EEOC’s current September 30 deadline.

But the EEOC has yet to even formally announce the reinstatement of Component 2, and we are still waiting on the technical specifications for data file uploads of Component 2 information, aren’t we? Yes, but that does not necessarily mean that employers cannot start preparing now.

The EEOC had proposed a new form and instructions for collecting Component 2 data, which were originally approved by the Office of Management and Budget (OMB). The court decision, assuming it stands, would effectively rescind OMB’s subsequent rescission of its approval. In other words, the previously approved materials become approved again. Prior to Component 2 being shut down, the EEOC had been preparing its systems to receive the new information and did publish technical specifications for the data upload files.

Luckily, those materials are still available, though they are not easy to find. To save you a long and painful internet search, you can simply click here and download the form and instructions for Component 2 from the OMB website. Even more detailed information about Component 2 reporting can be found in the EEOC’s Supporting Statement originally submitted to OMB during the approval process. The originally published technical specifications are harder to come by. Fortunately, BCGi downloaded them and you can too by clicking here.

In a nutshell, employers will likely be required to effectively “add” pay and hours worked data to the EEO-1 reports filed by May 31. In other words, you will report Component 2 information for the same employees for whom you submitted “Component 1.” The raw data necessary can be gathered now by pulling payroll information for the employee IDs in your 2018 EEO-1 snapshot. From there, you will need to do some extra work to translate actual pay figures into the EEO-1 pay bands.

As for the technical specifications necessary to prepare a data upload file for actual reporting, the EEOC is unlikely to completely re-tool their systems and processes more than necessary. It is a good bet that the technical specifications regarding Component 2 will be largely the same. We will have to wait and see whether and to what extent EEOC will break-out Component 2 for the 2018 reporting cycle or ask employers to resubmit Component 1 as well.

For certain, employers will be more likely to meet the EEOC’s Component 2 deadline if the raw data has already been gathered with an eye toward presenting it in something like the existing technical specifications. If you want to get started but need a little help, contact a Biddle EEO/AA specialist at staff@biddle.com.


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