As organizations change in size and scope, so do associated compliance requirements. Reevaluating and fulfilling new obligations for recordkeeping and reporting is essential to controlling liability. Organizations experiencing organic growth, receiving federal contracts or subcontracts, or involved in mergers and acquisitions should be especially aware of potential compliance changes.
The EEO-1 Joint Reporting Committee has determined which organizations are mandated to complete the Employer Information Report EEO-1 by September 30 of each year. In summary, and with few exemptions, private employers are legally required to file an EEO-1 report if, during the filing period of July through September, they:
- Employ 100 or more employees independently or with affiliated organizations legally constituting a single enterprise;
- Employ 50 or more employees, and
- hold federal contracts, subcontracts or purchase orders amounting to $50k or more; or
- serve as a depository of government funds in any amount; or
- are a financial institution issuing and paying for US Savings Bonds and Notes.
Over the last few years job categories and options for race and ethnic identification have changed. Employers should review forms and practices to ensure no misalignment exists between data collection and reporting. When filing, organizations should also ensure each individual meeting the Committee’s definition of “employee”, whether full-time or part-time, is accounted for on the EEO-1 report. Visual identification should only be used by employers following an employee’s decline to self-identify.
As establishments change in number or headcount, so may the amount or type of reports required to complete the EEO-1 report. Organizations should pay close attention to the breakdown of reports and make certain that appropriate templates are used each year. Although the EEO-1 report is a compliance requirement, it can also serve as a beneficial tool for benchmarking the effectiveness of internal equal employment efforts, ultimately helping to improve the organization.
For more information on this and other HR-related topics impacting government contractors, contact Kathy Albarado at Helios HR.
Hope A. Lane, CPA, leads Aronson LLC’s Government Contract Consulting Practice with over 20 years of broad-based experience in the government contracting arena. She assists clients in all areas of government contract-related financial compliance and contract administration.
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