In response to the call for public comments, The Institute for Workplace Equality submitted comments regarding the EEOC’s proposed update to the EEO-1 annual report. The OFCCP Institute’s feedback addresses concerns about the burden estimate and pay data proposed for collection. Data concerns include the type of data collected (i.e., W-2 earnings), the utility of pay banding, and the level of security employers should expect when submitting sensitive data. Supporting their comments, The OFCCP Institute included results of a member survey on system updates and costs that would be necessary for meeting the data requirements of the proposed report.
By Jana Garman, Consultant at DCI Consulting Group
