The Office of
Federal Contract Compliance Programs (OFCCP) requires certain
employers to submit EEO-1 reports to their office on an annual
basis. Any private employer who has federal contracts of greater
than $50,000 and more than 50 employees and any private employer,
without federal contracts, but with more than 100 employees is
required to submit an EEO-1 report. The EEO-1 report is used to
track demographic composition of workplaces.
Starting this
fall, employers will notice some changes on the EEO-1 reports.
Certain ethnic and racial categories have been renamed or
subdivided. Furthermore, the EEOC is now encouraging employers to
have employees identify themselves as belonging to a particular
racial or ethnic group for purposes of completing the EEO-1 report.
Previously, the employer was asked to complete the information based
on the employer’s observations alone. Such self-reporting on the
part of employees is entirely voluntary. In addition, the “Officer
and Manager” job category has been subdivided, to enable better
distinctions to be made between different levels of management.
Finally, business and financial jobs are now categorized as
“Professional,” instead of “Officials and Managers.”
The deadline for
filing the new EEO-1 report is September 30, 2007. However, the
EEOC has stated in the Federal Register that employers are not
mandated to “resurvey their entire workforce before submitting the
first EEO-1 form in the new format.”
Also, for those
employers with non-construction federal contracts, be aware that the
OFCCP has recently announced that it will be scheduling more
compliance evaluations for 2007. Any affected employer should be
receiving notice that they will be evaluated, and a scheduling
letter for the actual evaluation would come at a later date.
If you have any
questions about your obligations to the OFCCP, the new EEO-1 report,
an upcoming OFCCP audit or any other employment-law related
questions, please contact Bryn Wilson at
bwilson@poyners.com or
Susie Gibbons at
sgibbons@poyners.com.
