M A L Y   C O N S U L T I N G   L L C
March 15, 2006

Compliance Alert

Race/Ethnicity and Job Category Updates

The Equal Employment Opportunity Commission (EEOC) recently received approval for changes to the race and ethnic categories used on the EEO-1 Report (Standard Form 100, Employer Information Report). The revised report will be used for 2007 reporting. However, the current race/ethnicity categories will be used for 2006 reporting. Maly Consulting has created an information sheet with a comparison of the old and new categories available on our website at www.malyconsulting.com/Resources/2006-2007_Race-Ethnic_Categories.pdf.

EEO-1 Report data include all employees on the payroll on a date selected from July through September. Employers who are required to file the EEO-1 Report should ensure that their systems will allow reporting in the current categories for 2006 but will be updated with the new categories by September 2007. Although the EEOC stated that it will not mandate that employers resurvey their employees, it will be almost impossible to accurately file the 2007 EEO-1 Report without developing and issuing a new self-identification form.

In addition, the 2007 EEO-1 Report will use revised job categories including the separation of the "Officials and Managers" category into two new categories:
1.1  Executive/Senior Level Officials and Managers
1.2  First/Mid Level Officials and Managers
Because of this change and other more subtle job category changes, employers should take the opportunity before 2007 reporting to review the mapping of all of their job titles to EEO-1 job categories.

Information and copies of the 2006 EEO-1 Report are available on the EEOC website at www.eeoc.gov/eeo1survey. Information and copies of the 2007 EEO-1 Report are available on the EEOC website at www.eeoc.gov/eeo1.

The Office of Federal Contract Compliance Programs (OFCCP) issued a notice that it will be making changes to affirmative action regulations to coordinate its requirements with the EEO-1 Report race/ethnicity and job category changes. The notice, available at www.dol.gov/esa/regs/compliance/ofccp/eeo1rpt.htm, promises that employers covered under OFCCP regulations will be given a "reasonable transition period before any regulatory changes become effective."

Please feel free to contact us with any questions you may have regarding the upcoming race/ethnicity and job category changes.

(415) 454-4921
info@malyconsulting.com
Edward T. Correro, Esq.
www.malyconsulting.com
990 A Street, Suite 402 • San Rafael, CA 94901 • (415)454-4921 • Fax (415)454-4914
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