Per the new FAQ, dated 2/25/2021, these employees would not need to be included in the California reporting.
For example, an employee who lives in northern California, but commutes to an establishment or client site in Oregon, would not be included in the data filing. This differs from an employee who lives in California and teleworks from home or other California location; this employee would be included within the filing under the establishment which the employee reports to (same as their EEO-1 establishment).
We know it may be complex to determine which employees to include or exclude in the DFEH filing and which report to include them in, but we recommend that you focus on (1) where the employee does the work and (2) where the employee’s applicable establishment is located.
As a reminder, reports are due to DFEH by March 31st, unless an extension is requested and granted, which would defer filing until April 30th.
DCI will continue to monitor the changes to the California Pay Report website and resources. Stay tuned for additional details.
By Amanda Bowman, Associate Principal Consultant and Dave Sharrer, Senior Consultant
More information and assistance with filing can be found here: