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Compensation Portion of EEO-1 Form Delayed…but Not Gone

Jeremy Mancheski

The OIRA has indefinitely postponed the compensation portion of the EEO-1 Form.

In a pre-Labor Day letter addressing the EEO-1 form, the Office of Information Regulatory Affairs (OIRA) has postponed the compensation portion of the EEO-1 Form. While not entirely a surprise, the vague language of indefinite postponement speaks to the uncertainty in this administration with regard to the direction of both EEOC and OFCCP. Neither agency has permanent leadership in the Trump administration, and no new talk of the proposed absorption of OFCCP into EEOC has been reported. What is not uncertain is that this administration wishes to tackle equal pay.

What does this mean for you NOW?

• VETS-4212 Forms are still due by September 30, 2017.

• EEO-1 forms, albeit in the old format, are still due by March 31, 2018.

• There remains no EEO-1 form due in 2017.

What does this mean for you IN THE FUTURE?

Contractors should remain vigilant and continue to monitor pay data in anticipation of enforcement.

In her August 29 letter Acting EEOC Chair Victoria Lipnic said:

The EEOC remains committed to strong enforcement of our federal equal pay laws, a position I have long advocated. Today's decision will not alter EEOC's enforcement efforts.

I had consistently urged OMB to make a decision on this matter so that stakeholders would be aware of their reporting obligations.

Going forward, we at the EEOC will review the order and our options. I do hope that this decision will prompt a discussion of other more effective solutions to encourage employers to review their compensation practices to ensure equal pay and close the wage gap. I stand ready to work with Congress, federal agencies, and all stakeholders to achieve that goal.

Consider this delay as symptomatic of an agency and administration that is struggling to find its footing and leadership. Most major shifts in government experience delays and revisions. In this instance, contractors are given more time to review and analyze compensation within their organizations.

The current administration has made it abundantly clear that compensation will be part of the dialogue with contractors. First daughter and trusted advisor Ivanka Trump released a statement:

Ultimately, while I believe the intention was good and agree that pay transparency is important, the proposed policy would not yield the intended results. We look forward to continuing to work with EEOC, OMB, Congress and all relevant stakeholders on robust policies aimed at eliminating the gender wage gap.

Her equal pay rhetoric was clear during the presidential campaign and rings true to this day. Further, nearly all current OFCCP compliance reviews are focusing a larger portion towards compensation with most having interviews between compliance officers and site Human Resources staff.

While this delay saves us all time next year, it is imperative that we continue to monitor compensation. OutSolve remains ready to provide services and support on VETS-4212 and EEO-1 reporting as well as compensation analysis and preparedness. Please contact either your consultant or me if you have any questions.

Jeremy Mancheski

President

OutSolve

jmancheski@outsolve.com

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