The following post was authored by Cindy Karrow, SPHR, SHRM-SCP, Senior Consultant at Berkshire Associates Inc.
The Joint Reporting Committee opened the EEO-1 website for 2015 reporting earlier this week. Many employers were surprised to learn there were changes made to the reporting requirements. These changes may be difficult for some employers to manage. The EEO-1 site identifies the changes on its main web page, which include:
- Federal Tax ID (also known as EIN or FEIN) number is now required for each EEO-1 filed.
- This presents a problem for employers who file using the electronic upload option. The data requirements for this file did not include a required field for EIN until August 25, 2015, when the specifications for the file were posted on the EEO-1 site. No advance notice or explanation was provided to employers for this change.
- Employers who file by entering the information directly into the EEO-1 website screens will have a field to complete for the EIN.
- Companies may no longer file more than one EEO-1 report for the same address if the North American Industrial Classification System code (NAICS) is the same for the duplicate reports. The NAICS code best describes the main product, service, or activity at an establishment.
- Employers must consolidate the employee data into one EEO-1 report even if they filed multiple reports in the past for the same address.
- Another option offered by the EEO-1 notification letter is for the employer to update or change the NAICS code(s) used for the duplicate reports to make them different and to more accurately reflect the business activity. Employers are cautioned that NAICS codes may be used by a company for more than just filing EEO-1 reports, so they should check with other departments that may be affected by such a change.
The Joint Reporting Committee provides an alternative for employers who are unable to meet any of the EEO-1 reporting requirements. Unfortunately it is burdensome as well. Employers are referred back to the instructions for completing an EEO-1 report. They may submit in writing a detailed alternative proposal for compiling and reporting the required information. A postal address is provided for such a request. Visit the EEO-1 website under Item 5 Requests for Information and Special Procedures for more information.
For more information about EEO-1 requirements, please contact a Berkshire Associates’ compliance expert at 800.882.8904.