Effective Date: March 31, 2018 is the first due date for the 2017 EEO-1 Reporting Cycle

On September 29, 2016, the Equal Employment Opportunity Commission (EEOC) announced that certain employers will be required to provide summary pay data and hours worked as part of the EEO-1 report.  Below are the important changes.

Private companies, including federal contractors and subcontractors, with 100 or more employees will report summary pay data and hours worked starting with the 2017 EEO-1 reporting cycle. Federal contractors and subcontractors with 50 to 99 employees are not required to submit summary pay data and hours worked, but will continue to provide gender and race/ethnicity information as part of the EEO-1 report. Federal contractors and subcontractors with 49 or fewer employees and companies without federal contracts that have 99 or fewer employees are not be required to complete the EEO-1 report.

In the past when filing EEO-1 reports, companies used a snapshot of their workforce between July 1 and September 30. Starting with the new 2017 EEO-1 reporting cycle, the workforce snapshot period will be taken between October 1 and December 31, 2017.

Summary compensation data will be provided by pay band (i.e. (1) $19,239 and under, (2) $19,240-$24,439, (3) $24,440-$30,679, etc.) and EEO category. Employers will use pay reported in Box 1 of the W-2 form to determine which pay band each employee belongs. Please note: compensation earned after the last full pay period in December that is paid in the next calendar year should be reported for the same year in which it is reported on the W-2 form.

Hours worked will be reported by adding the total number of hours worked by all employees within each pay band and EEO category for the W-2 reporting year. For exempt employees, companies can either report 20 hours per week for part-time employees and 40 hours per week full-time employees or they can report the actual hours worked. Employers are required to report the actual hours worked for all non-exempt employees.

Here is a link to the sample 2017 EEO-1 form: https://www.eeoc.gov/employers/eeo1survey/upload/component-1-and-2-sample-2017-eeo1-report.pdf

Here is a link to the Questions and Answers from the EEOC’s website: https://www.eeoc.gov/employers/eeo1survey/2017survey-qanda.cfm

Maly Consulting will be offering the service of completing and filing the new EEO-1 Report for both government contractors and companies without government contracts. The process will be simple – send us a data report from your HRIS and/or payroll system with employee information, and we take care of everything else for you. We also provide non-discrimination pay analysis services, so you can be aware of (and be able to fix) potential issues before the government receives your data. For pricing information, please contact us.

If you have any questions, or would like to discuss this Compliance Alert further, please let me know.

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