If your Florida company employed 100 or more employees (and federal contractors with more than 50 employees) for all pay periods in the 4^th Quarter of 2017 and 2018, then you need to learn how to report your organization’s compensation data to the Equal Employment Opportunity Commission (EEOC).  Reporting for both years (2017 and 2018) must be submitted on or before September 30, 2019.

The EEOC recently updated the Component 2 EEO-1 Online Filing System website to include resources for employers, including a section on Frequently Asked Questions, a sample forms, and instruction booklet.  See the Fact Sheet Summary.

Step 1: Determine if your company employs at least 100 employees during the pay period selected in the 4^th quarter of each year (2017 and 2018).  Full time and part-time employees need to be counted.  If less than 100 employees were employed during any pay period in the 4^th quarter, your company can select that pay period as the basis for your employee count, which will exempt you from reporting.  The Component 2 pay period does not need to be the same pay period that you used during your standard EEO-1 reporting in May.  However, if there is no pay period that could possibly put you under the 100 employee count compliance threshold, it might be easier to use the same period for which you had already pulled an EEO-1 report.

Step 2:  Pull an EEO-1 report for the pay period to identify all employees in the selected pay period, as well as their EEO-1 ethnicity category and gender. Use the compensation pay bands from the sample form (using the earning from the “W2 – Box 1 – Wages, tips, other compensation” as the measure of pay for Component 2), tally the total number of employees who fall into each of the 12 compensation bands by the 10 different job categories.  If there is no employee in a compensation band, employers should leave the cell blank.

Step 3: The second portion of Component 2 reporting involves reporting hours-worked data.  Pull a year-end report showing all hours worked by non-exempt employees during the selected pay period.  Each cell on the hours-worked matrix corresponds to a cell on the summary compensation data matrix. The hours worked during that year by all the employees counted in the cell on the summary compensation data matrix should be totaled and then recorded in the corresponding cell on the hours-worked matrix. Read the FAQs.  Hours-worked data is reported to account for part-time and partial-year employment. For non-exempt employees under the Fair Labor Standards Act (FLSA), employers must report actual hours worked.  For exempt employees, you can report full time as 40 hours per number of weeks employed (or use actual hours).  Check the FAQs for other questions.

Step 4: Add all of your compensation and hours worked summary data onto a CSV data file that will be uploaded on the website.  Use the template provided.

Step 5: Set up your online account.  Go to https://eeoccomp2.norc.org/Login and click on first time user and create a user name and password.  If help is needed, contact the help desk by phone at 877-324-6214 or email your question to [email protected].

Step 6:  Log on and upload your data.  You will enter a separate submission for 2017 and for 2018, which are both due by September 30, 2019.   After each submission, you must fill out the Certification Page and select “Certify” in order for the submission to be accepted (after which you will not be able to edit data for that submission).   Don’t forget to save a copy of the submitted data for your company’s records.

Unsure about what to do, or want some assistance to get this mandate done?  Just give us a call at Consultstu LLC (727) 350-0370 and we can help.