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OFCCP Officially Reports It Will Not Use EEO-1 Component 2 Pay Data

Via Federal Register notice, OFCCP has officially stated the Agency

"will not request, accept, or use Component 2 data, as it does not expect to find significant utility in the data given limited resources and its aggregated nature, but it will continue to receive EEO-1 Component 1 data.

The notice is a welcomed confirmation for federal contractors that had concerns about OFCCP’s intentions with respect to the recently filed compensation data.

The notice reflects that OFCCP

"reviewed the parameters of the EEO-1 Component 2 data collection and has determined that it does not find Component 2 data necessary to accomplish its mission to ensure federal contractors are not engaged in unlawful pay discrimination.

While the use of the collected pay data seems settled for OFCCP, at least at this point, the future of pay data reporting in general remains up in the air.

This week EEOC held a public hearing on the matter, where the Commission heard testimony and feedback on the current EEO-1 Component 2 Pay Data collection form and reporting of pay data in general.

In addition, as ordered, EEOC continues to collect and analyze pay data as part of its evaluation of the utility of the Component 2 collection and potential modifications to the process and form.

As we learn more about EEOC’s intentions and new developments we will continue to bring you updates – so as always, stay tuned for more!

Jackson Lewis P.C. © 2020National Law Review, Volume IX, Number 326


About this Author

Laura Mitchell, Jackson Lewis, Management Representation lawyer, Contractual Drafting Attorney

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...