Today, the EEOC published a Notice of Information Collection regarding the EEO-1 in the Federal Register. Notably missing from the notice was a request to renew the authorization to collect Component 2 (pay & hours) data. While they requested renewed authorization to collect Component 1 (race & gender) data as their authorization expires at the end of the month, they noted that their revised burden analysis filed earlier this week shows Component 2’s “unproven utility” is far outweighed by the burden imposed on employers with the reporting obligation. (The actual analysis showed more than a 1000% increase in burden estimate, from $53.5 million per year to over $600 million per year.) The EEOC concludes it needs to first study the ongoing Component 2 data collection before deciding whether to submit for a renewed authorization request to the OMB.
IMPORTANT NOTE – Employers currently subject to EEO-1 Component 2 are still required to submit 2017 and 2018 pay data by September 30, 2019.