MVPD Annual EEO Program Reports and SIS Responses Due Sept. 30, 2013

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The Federal Communications Commission’s (FCC) equal employment opportunity (EEO) rules for multi-channel video program distributors (MVPD) require MVPD employment units with six or more full-time employees to file an Annual EEO Program Report, FCC Form 396-C. This is an electronic filing that must be submitted to the FCC on or before Sept. 30, 2013 of each year. The FCC has released a Public Notice to remind MVPDs of this filing deadline, and to identify the employment units that will also be required to submit responses to a Supplemental Investigation Sheet (SIS) with their FCC Form 396-C filings.

The SIS is an electronic form that will be attached to the FCC Form 396-Cs of the employment units identified in the Public Notice. It has three parts:

Part I of the SIS requires one or more written job descriptions for positions in specified job categories. This year, the FCC has requested that responding employment units submit one written job description for a position in the Technicians job category.

Part II of the SIS requires narrative responses to questions about the unit’s EEO program. There are nine questions in Part II of the SIS, of which the FCC typically selects three to be answered in a given year. This year, the FCC has requested that employment units provide answers to the following three questions:

Question 4: Explain the employment unit's efforts to promote in a nondiscriminatory manner to positions of greater responsibility.
 
Question 7: Describe the responsibility of each level of the employment unit's management with respect to application and enforcement of its EEO policy and explain the procedure for review and control of managerial and supervisory performance.
 
Question 8: Describe the manner in which the employment unit conducts its continuing review of job structure and employment practices.

Finally, Part III of the SIS requires employment units to submit a copy of their EEO Public File Report for the previous twelve month period.

If you have any questions about the annual FCC Form 396-C filing or responding to the SIS, please contact Liz Drogula.

Topics:  Distributors, EEO, FCC, Multichannel Video Programming, Video

Published In: Communications & Media Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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