Earlier today, the Equal Employment Opportunity Commission announced changes to its EEO-1 reports which will require larger employers (i.e., those with over 100 employees) and federal contractors to provide additional EEO-1 data regarding pay ranges and hours worked. According to the EEOC, these new pay data requirements will become effective with the September 2017 EEO-1 report. While the EEOC suggests that this additional pay information will assist employers in evaluating their pay practices and avoiding pay discrimination, there can be no doubt that both the EEOC and the OFCCP will utilize and evaluate this data in the investigation of existing charges and in pursuit of both individual and pattern and practice pay discrimination cases. These proposed changes are due to be published in the Federal Register on February 1 with a public comment period through April 1.


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