On April 25, 2019, the District Court for the District of Columbia issued its ruling regarding the timeframe to collect pay and hours data in connection with the Revised EEO-1 Report. The order provided that the EEOC begin collecting 2017 and 2018 Component 2 data by September 30, 2019. The Court gave the EEOC the option of collecting 2019 Component 2 data in the 2020 reporting period in lieu of collecting 2017 data by September 30, 2019, provided that it notifies the Court and the Plaintiffs of its intention to do so by May 3, 2019.
There has been no indication as to whether the Department of Justice, which represents the EEOC’s interests, will appeal the ruling.
What should employers do now?
Employers should begin making preparations to collect, aggregate, and report on pay and hours data for 2018 immediately. This will permit adequate time internally to take all steps needed to prepare, report or accumulate the necessary data to send to external vendors. This will also permit adequate time to review all of the databases and other programming in order to meet the demands of providing data required for Component 2 for each reporting location. Identifying and committing resources will be required to work on the data, aggregate the information, and then test it before the submission deadline of September 30, 2019.
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Elliot N. Dinkin
What’s Dinkin Thinkin covers a variety of topics including: compensation, benefits, retirement, management, sales, and marketing.
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