Planning for gender equity in compensation and all employment decisions is critical for every employer, and is worth discussing with your professional advisors as the law changes. Starting in 2017, employers with more than 100 employees who submit EEO-1 reports will be required to electronically submit additional data to be used by the Office of Federal Contract Compliance Programs (OFCCP) and the Equal Employment Opportunity Commission(EEOC) to assess and investigate claims of discrimination. Although employers will not be required to collect any data they would not otherwise collect in the normal course of business, they will be required to report the following new information regarding their employees:
- total actual earnings, which includes but is not limited toovertime, severance pay, shift differentials, and bonuses
- hours worked
Both the OFCCP and the EEOC will be developing a tool to perform an initial pay equity analysis that allows their investigators to look at actual pay as compared to aggregate industry data and/or relevant geographic data. Employers opting not to conduct their own pay equity analysis may find themselves on the defensive when the EEOC and/or OFCCP come knocking. Written comments regarding the revision of the EEO - 1 Report can be submitted to the EEOC online here until April 1, 2016, at 11:59 p.m.
Please see full publication below for more information.
