DCI Consulting representatives recently contacted the NORC helpdesk for guidance after being unable to view or download draft or final EEO-1 Component 2 reports in the NORC system. The helpdesk responded timely, but conveyed that the download of draft or final reports was not an option and employers instead should make sure they retain a copy of the “exact file they uploaded for both reports on their end, for their records”.
As this is a big departure from the typical filing process for EEO-1 Component 1, DCI requested that NORC post this information to employers through an FAQ, as well as citing it in another related guidance document like the user guide or instructions. It is unclear if this feature was “forgotten” by EEOC or NORC or just deemed the ability to view or download final reports unessential given timeline, resources, or other reasons.
There are many reasons why organizations would want to be comfortable with the data before importing (or manually entering) into the EEO-1 Component 2 system designed by NORC. Not only is a draft review unavailable, but edits cannot be made after upload but before certification. It is recommended that data and draft reports are thoroughly reviewed and approved prior to importing into the system. Further, in addition to NORC’s recommendation to keep a copy of the “exact file”, DCI recommends having a copy of the following on file:
- NORC system web confirmation page saved for both 2017 & 2018;
- CSV file used for batch upload (if applicable);
- A copy of ‘mock’ reports, if applicable based on the system or vendor utilized to prepare these filings.
Another consideration, until OFCCP’s revised scheduling letter is approved, OFCCP will have to tell contractors that they do not need to submit Component 2 EEO-1 reports in response to item 15 of the scheduling letter, given contractors do not have the ability to download or view a final copy from the NORC system
Stay tuned as we learn more about this matter.
By Amanda Bowman, Associate Principal Consultant at DCI Consulting Group
