Aggregating Pay Data in the New Year: Time to Get Your House in Order

Q.  I work for a company that employees more than 100 employees.  I heard somewhere that we now have to include pay data and hours worked on our EEO-1 forms.  Is that true?

A. Yes!  Beginning with calendar year 2017, employers with 100 or more employees will be required to submit pay data and hours worked in the newly revised EEO-1 report. Adding pay data to the form means that the EEOC and the OFCCP will now have a snapshot of employers’ pay practices across protected categories of sex, race and ethnicity.

The 2017 EEO-1 report will not need to be filed until March 2018.  However, it is important that employers prepare now so that their pay data for calendar year 2017 is compliant.

Click here for a Pepper Client Alert discussing this issue in more detail.

-Tracey E. Diamond


New Rules on Sex Bias for Federal Contractors

Q.  As a federal contractor, do I need to worry about complying with any special rules with respect to sex discrimination?

A.  The Office of Federal Contract Compliance Programs (OFCCP) recently revised rules on sex discrimination, which took effect on August 15.  The revised rules require covered employers to take certain steps to make sure that sex discrimination does not occur in the workplace.  Given these revisions, we expect that the OFCCP will focus on sex discrimination issues in future compliance audits.

For details on the revisions to the OFCCP rules and what your company should do to maintain compliance, please check out this Pepper@Work Alert from my colleague, Lee Tankle.