As we previously reported, the annual EEO-1 Reporting portal has opened and along with it some changes to the reporting requirements.  Probably the most impactful change is the new requirement that 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 more than one of the entities.   In other words, if your company has multiple entities at the same address and those entities, while legally distinct, engage in the same services, activities or product development you must now file a single consolidated report. For companies with complex organizational structures and/or significant acquisitions, this will require detailed review and assessment of your filings.

There is a mechanism for requesting a variance from this requirement, however the company will need to provide a basis to support the claim of an “undue hardship” which may require detailed company structure information to be submitted to the Commission for review.

In any respect, given all of the changes with this year’s reporting process and procedures, employers cannot wait to the last minute to prepare their reports and should be working to get them finalized now.

 

 

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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.