September 17, 2019

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EEOC Announces Plans to Collect 2017 and 2018 Pay Data by September 30, 2019

On May 1, the EEOC announced plans to collect pay data for both calendar year 2017 and calendar year 2018 by September 30, 2019. A copy of the announcement scheduled to be published in the Federal Register on May 3 is available here.

Given this development, a government appeal seems unlikely, but we will continue to monitor and will update in the event of an appeal.

What does this mean for employers? All employers with 100 or more employees must now collect and submit data for pay and hours worked (Component 2) in calendar year 2017 and calendar year 2018, by September 30, 2019. The EEOC expects to open the portal for submission of Component 2 data in mid-July 2019.

The filing deadline for EE0-1 Component 1 (demographic workforce) data remains May 31, 2019.  Employers will submit the Component 1 data separately from the Component 2 data, as the deadline to submit Component 1 data will pass before the EEOC begins collecting Component 2 data and a third party vendor will be used for the submission of Component 2 data.

 

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Stephanie E. Lewis, Jackson Lewis, Managing Principal, Policy Litigation Attorney,
Office Managing Principal

Stephanie E. Lewis is the Office Managing Principal of the Greenville, South Carolina, office of Jackson Lewis P.C. She represents employers in employment litigation and advises clients on preventive practices and policies to avoid litigation.

Ms. Lewis has handled all aspects of employment law but focuses on sexual harassment, pay discrimination, and disability discrimination issues in the automotive, manufacturing, retail, and pharmaceutical industries. She regularly presents on employment-related topics to Bar and...

864-672-8048
K. Joy Chin, Jackson Lewis, wage benefits lawyer, affirmative action attorney
Principal

Joy Chin is a Principal in the Long Island, New York, office of Jackson Lewis P.C. Since joining the firm in 1995, her practice has been devoted exclusively to employment law and related litigation and the firm’s regulatory practice.

Ms. Chin has litigated matters before local, state and federal administrative agencies and in state and federal courts. Ms. Chin is a frequent speaker on affirmative action and creating lawful diversity programs and spends much of her time counseling employers on issues relating to diversity, EEO, and affirmative action compliance. Prior to joining Jackson Lewis, Ms. Chin was an Assistant District Attorney in Kings County, New York, and in Nassau County, New York.

631-247-4613
Principal

Matthew Camardella is a Principal in the Long Island, New York, office of Jackson Lewis P.C. He directs the preparation of more than 400 AAPs each year and has defended hundreds of OFCCP audits for a broad range of employers across the country.

In addition, Mr. Camardella serves as the Practice Group lead on responding to OFCCP allegations of class-based discrimination. He spends significant time counseling clients about the design and implementation of company-wide AAP structures, applicant flow tracking systems,...

631-247-0404
Laura Mitchell, Jackson Lewis, Management Representation lawyer, Contractual Drafting Attorney
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Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and government contractor compliance.

Ms. Mitchell is a Principal in the firm’s Affirmative Action and OFCCP Defense practice group, representing government and non-government contractors in Office of Federal Contract Compliance Programs (OFCCP) matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming...

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