Broadcast Station Update: EEO Reports Due April 1


-Annual EEO Public File Report Deadline—April 1 Affected States: Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas

-Mid-Term EEO Report—April 1 TV Stations in Delaware and Pennsylvania

By April 1, 2011, radio and television Station Employment Units in the listed states must prepare and place in their Public Inspection File and post on their website, if they have one, their FCC Annual EEO Public File Report. A Station Employment Unit (SEU) is a group of stations, under common control, serving a common area and sharing at least one employee. If an SEU includes stations in different states or territories with different filing deadlines, the SEU can select which filing deadline it will use. Once selected, the Annual Report filing deadline should be consistently applied for all future EEO Annual Reports. The states with the April 1 EEO Public File Report deadline are: Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, and Texas.

Background on EEO requirements

The FCC's EEO rule requires all radio and television SEUs, regardless of staff size, to afford equal employment opportunity to all qualified persons and to practice nondiscrimination in employment. The Annual EEO Public File Report summarizes the activities of SEUs with five or more full-time employees ("Nonexempt SEUs") that demonstrate compliance with the FCC's three-pronged outreach requirements.

All Nonexempt SEUs must comply with the following “prongs” of the EEO outreach requirements: (1) broadly and inclusively disseminate information about every full-time job opening except in exigent circumstances (commonly referred to as the requirement for “ Wide Dissemination”); (2) send notifications of full-time job vacancies to recruitment organizations that have requested notice; and (3) participate in a specified number of outreach initiatives (so-called “Supplemental Efforts”) from the FCC's menu of such options during each of the four two-year segments that comprise a station's eight-year license term.

The Supplemental Efforts must be conducted even if a station has had no job openings in the prior year in an effort to educate the community as to the types of jobs available at broadcast stations, the training and qualifications required for such jobs, and the way in which people can find out about and apply for broadcast openings.

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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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