On September 9th, the EEOC announced that it will halt the collection of pay data during future reporting periods due to the high burden on employers and the unproven usefulness of the program. This announcement may mean that pay data submission will be a one-time effort that may not need to be repeated in 2020.
As of right now, employers should keep two important points in mind: nothing about the announcement relieves employers of the current obligation to have provided 2017 and 2018 pay data to the EEOC by September 30th, 2019, and it is possible that a court or future administration intervenes and forces the EEOC to once again open up the EEO-1 to require Component 2 data in 2020 or beyond.
HR Works will continue to assess the situation and provide necessary updates.
Although it is likely that collection of pay data may not be required in 2020, it is strongly recommended that employers continue to make it a priority to review and audit their current pay systems and identify and address any areas of pay disparity. By conducting an audit of your pay practices, you will be able to determine whether any pay gaps exist that might catch the eye of the federal government, if, or when you are forced to turn over this information.
Employers should work with legal counsel to conduct this review under the protection of the attorney-client privilege. Due to the increased complications caused by varying state legislative developments, it is strongly recommended that employers involve their attorney in this analysis early on.
HR Works Can Help
Employers who would like information on attorneys that can assist with an audit of their pay practices may contact the Virtual Helpline at 585-381-8340 Opt. 1 or via email at Helpline@hrworks-inc.com.
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