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“ISSUE: Trump Administration Torpedoes Compensation Portion of EEO-1 Report Due March 31, 2018”

By Pamela M. Ploor

On August 29, 2017, the Office of Management and Budget (OMB) delayed the new compensation and hours component of the EEO-1 report that the Equal Employment Opportunity Commission (EEOC) revised on September 29, 2016. The stated reasons for the delay were concerns that the compensation and hours data collection was impractical, overly burdensome, and did not sufficiently protect privacy and confidentiality. 

IMPACT: The OMB action essentially cancels the compensation and hours component of the report. EEOC must submit a new EEO-1 data collection package for OMB to review and publish a notice in the Federal Register announcing the delay of the implementation of the changes and the authorization for use of the prior EEO-1 report form. For now, employers with 100 or more employees and federal contractors with 50 or more employees should plan to use the prior EEO-1 report for their next filing on March 31, 2018. While this is great news, the march toward pay transparency and pay discrimination claims continues. Increasing numbers of state and local laws, activist shareholders of public companies, and company announcements of the results of their pay equity analyses continue the pay equity pressure on companies. Privileged compensation analyses are still recommended.

If you have any questions on the EEO-1 report form or on pay equity, please contact Pamela Ploor at 414-277-5661 / [email protected] or your Quarles & Brady attorney.

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