The EEOC has released much-anticipated guidance for the new EEO-1 “Component 2” compensation data reporting requirement in the form of “Frequently Asked Questions” (FAQs). Some of the guidance is surprising. For instance:
- Employers are not required to use the same snapshot population as they used when filing the corresponding Component 1 reports, though they may if they choose.
- It appears that the EEOC is not going to stitch together the 2017 and 2018 headcount and compensation components.
- “Hours worked” does not have to include paid time off, such as sick leave or vacation, though the guidance is unclear on whether or not including such hours is actually prohibited.
EEOC’s new FAQs are available online at https://eeoccomp2.norc.org/faq.html.