All employers that are required to submit an EEO-1 federal report -- employers of 100 or more or federal government contractors and first-tier subcontractors with 50 or more employees and at least $50,000 in federal government contracts -- must now also file  the newly required Component 2 data report regarding wages for 2017 and 2018.  The report must be submitted by September 30, 2019.  As with the EEO-1, the Component 2 information can be filed electronically using the EEOC’s web portal.  While the 10 employee categories on the form remain the same, the wage data for each category must be subdivided into 12 different pay ranges, and the reporting made by sex, race, and ethnicity.  

Need for Data Analysis

Because the EEOC intends to use the comparative wage and salary data to evaluate possible pay inequities based on race, sex, and ethnicity, you should review your data for the same issues prior to filing. 

If your data shows significant disparities, the EEOC may ask you to explain the reasons for them.  Prior review and evaluation of your data will give you an opportunity to be ahead of any EEOC inquiry in three important ways:  (1) knowing whether your data may prompt questions from the EEOC; (2) determining the cause of any significant disparity (i.e., is it possibly based on impermissible considerations  or, rather,  factors other than race, sex, or ethnicity); and (3) whether permissible or not, what you want to do about it (or what you can do about it).

These days, workplace diversity and pay equity are two of the hottest workplace issues after sexual harassment.  Knowing if you have a problem and addressing it before the government or a private party sues you will save time and money.  Moreover, your self-prompted corrective actions may improve employee relations and workplace culture.