An outside organization commissioned by the Equal Employment Opportunity Commission (EEOC) to evaluate the agency’s 2017-2018 collection of pay and hours-worked data on the EEO-1 Report (Component 2) has issued a report concluding that the data are unsuitable for determining whether it is likely that an employer has engaged in unlawful conduct.
The long-awaited report by a panel convened by the National Academies of Sciences, Engineering, and Medicine’s Committee on National Statistics (NAS) includes an extensive discussion of the data collected, how it might be used, and its limitations. And while the panel concludes that the data are unsuitable for determining unlawful employer conduct, the report does suggest that the data might be suitable in identifying potential pay gaps that may be appropriate to investigate further.
The report also makes numerous recommendations to be considered in the event the EEOC decides to move forward with any future pay data collection efforts. Among these recommendations are collecting individual-level pay data, which the panel believes would be less burdensome for employers to submit, and using Standard Occupational Classification system categories instead of EEO-1 job categories.
Members of the Center for Workplace Compliance (CWC) can read more here.