Earlier this month, the FCC imposed a $20,000 fine and detailed reporting requirements on an Illinois radio licensee. Under Section 73.2080(c)(1)(ii) of the FCC’s Rules, a licensee must provide notices of job openings to any organization that “distributes information about employment opportunities to job seekers upon request by such organization,” and under Section 73.2080(c)(3), must “analyze the recruitment program for its employment unit on an ongoing basis.”

The Media Bureau discovered the violations during an EEO audit covering the period August 1, 2009 through July 31, 2011. The audit revealed that the licensee had filled 36 full-time positions at its stations, but had not provided notification to organizations that had asked for that information for 33 of these vacancies. The number of organizations that did not receive requested information ranged from 21 organizations for some vacancies to two organizations for other vacancies. The FCC also found that the licensee had not sufficiently analyzed its recruitment program, nor had it corrected problems in its process for “achieving broad outreach to potential applicants.”

The FCC does not have a base fine for EEO violations. Therefore, the Commission looked at prior decisions and the circumstances of this case in assessing a $16,000 fine for failing to provide vacancy information to requesting organizations, and a $4,000 fine for failing to self-assess the effectiveness of its EEO program. In addition, the FCC required the licensee (and any successor licensee of any or all of the stations) to submit annually for the next three years a sworn statement to the FCC including: (1) the EEO public file report, (2) dated copies of communications announcing each full-time vacancy, (3) the recruitment source that referred the hiree and the job title of each full-time vacancy, (4) the number of people interviewed for each available position and the person or organization who referred each interviewee, (5) a list of all sources requesting job notifications, and (6) a list of who the licensee notified of job vacancies.