|
|
|
|
|
Although the new categories are included on the 2007 EEO-1 report, the Equal Employment Opportunity Commission (EEOC) is not mandating that employers re-survey their workforce. If an employer is not using the new categories, they may simply enter zeroes in the Two or More Races and Hawaiian/Pacific Islander categories. The 2007 EEO-1 does divide "Officials and Managers" into two levels based on responsibility and influence within the organization: "Executive/Senior Level Officials and Managers" and "First/Mid-Level Official and Managers." This change in reporting is mandatory on the 2007 EEO-1.
The Office of Federal Contract Compliance Programs (OFCCP) has announced Interim Guidance that basically says it will not cite any contractor for non-compliance if it uses the new race and ethnic categories, but the agency does not explain how to actually use the new categories in an affirmative action plan. See the actual text at http://www.dol.gov/esa/regs/compliance/ofccp/EEO-1%20Interim%20Guidance.htm. The OFCCP and EEOC have pledged to coordinate their data collection efforts and the EEOC's
|
|
|
|
|
|
|
|
|
|
|
annual EEO-1 Information Form is used by the OFCCP as a part of their audit selection process. The OFCCP expected to release proposed regulations in March and final regulations in July, but as of the beginning of August, not even the proposed regulations have been released.
Where does this leave contractors who desire to comply with the applicable regulations? A contractor could require employees to self-identify twice, once using the new EEOC race/ethnic categories and secondly using the older five categories for affirmative action purposes. In our experience, this option has not been adopted by many contractors. It creates two sets of confusing records and problems for Human Resource Information Systems (HRIS) to maintain two sets of race/ethnic choices for each applicant/employee. Many HRIS have already implemented the new race/ethnic categories and divided Officials and Managers into two sub-groups. Most contractors have chosen to complete their affirmative action plans using whatever categories they are tracking in their HRIS system. A number of our clients using the new categories have been audited by the OFCCP
|
|
|
|
|
|
|
