Q. Please explain the new requirements for reporting pay data with the EEO-1 Form.
A. During the Obama administration, the Equal Employment Opportunity Commission (EEOC), in an effort to address pay discrimination, sought to require organizations that file EEO-1 forms (i.e., those with at least 100 employees or federal government contractors with 50 or more employees) to report additional pieces of information — W-2 wage data and hours worked within 12 pay bands by sex, race and ethnicity for each of the 10 EEO-1 job categories. The purpose of this requirement was to provide the EEOC with information to assess pay disparities along sex and race lines. The pay data collection requirement was set to be implemented on March 30, 2018, but the Trump administration’s Office of Management and Budget (OMB) stayed the requirement on August 29, 2017, concluding that it violated the Paperwork Reduction Act.
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