The Equal Employment Opportunity Commission has made signifi cant changes to its EEO-1 reporting system. Since 1966, private employers with 100 or more employees and federal contractors with more than 50 employees have reported annual data about the number of employees in occupational categories and subcategories. This year a revised EEO-1 report form will be in use. It contains a more complicated racial and ethnic classifi cation system, refl ecting data from the 2000 Census and changing workforce demographics, and redefi nes employees heretofore classifi ed as “Offi cials and Managers.” Although employers are not required to resurvey employees in 2007, they must report current data on the revised form starting with the report due on September 30, 2007. Employers should develop a new survey system as soon as possible to conform to the new classifi cation system.
Racial and Ethnic Classification Changes
The new reporting system changes the racial and ethnic classifi cation system used in prior reporting years.
- Renamed Race Categories—The new EEO-1 form renames “Black” as “Black or African American,” and “Hispanic” as “Hispanic or Latino.” Also, “Asian or other Pacific Islander” is now separated into “Asian” and “Native Hawaiian or other Pacific Islander.” If an employer does not resurvey employees for the 2007 report, it should report employees who previously self-identifi ed as “Asian or Other Pacific Islander” as “Asian” for purposes of the 2007 report.
- Two-question Format—In order to yield more accurate data about Hispanic and Latino employees, the revised EEO-1 form requires employers to give employees who self-identify their ethnic background as “Hispanic or Latino” or “Not Hispanic or Latino” the opportunity to self-identify according to race. Although the race information obtained will not be reportable on the new EEO-1, such information that corresponds to the racial categories in the “Not Hispanic or Latino” category must be preserved as an employment record.
- New “Two or More” Race Category— To obtain more accurate information about individuals with multiracial backgrounds, the EEO-1 form now requires employers to report the number of employees who claim “Two or More Races.” An employer may ask such employees to specify particular races, but is not required to do so. Employers should preserve any specifi c race information as an employment record.
Job Classification Changes
The new EEO-1 form creates new categories for reporting “Offi cials and Managers.” Previously, employers have reported “Offi cials and Managers” in one category without regard to differing levels of responsibility, compensation and skills. Now the category “Offi cials and Managers” is separated into “Executive/Senior Level Offi cials and Managers” and “First/Mid Level Offi cials and Managers.” Also, nonmanagerial individuals in business and fi nancial occupations previously reported in the “Offi cials and Managers” category must now be reported in the “Professional” category.
- Executive/Senior Level Officials and Managers—This category includes employees who plan, direct and formulate policy, set strategy and provide overall direction. They reside in the highest levels of organizations and plan, direct or coordinate activities with the support of subordinate executives and staff managers. In larger organizations, they include CEOs and individuals within two reporting levels of the CEO whose responsibilities require frequent interaction with the CEO. Examples are: CFOs; COOs; presidents or executive vice presidents of functional areas or operating groups; chief marketing offi cers; chief legal offi cers; and managing partners.
- First/Mid Level Officials and Managers— This category includes the next lower level of managers who oversee and direct the delivery of products or services at a regional or divisional level, and who typically lead major business units. They implement policies, programs and directives through subordinate managers and within the parameters set by top management. Examples are vice presidents and directors; regional or divisional controllers; treasurers; and human resource, information systems, marketing and operational managers. They also include employees who report directly to middle managers. Examples are fi rst-line managers; team managers; unit managers; operations and production managers; call center or customer service managers; technical support managers; and branch or product managers.
- Categorization of Business and Financial Occupations—Nonmanagerial individuals in business and fi nancial occupations previously reported in the “Offi cials and Managers” category must now be reported in the “Professional” category.
To comply with these changes, employers will need to resurvey their workforces to gather the necessary racial and ethnic data. However, for the EEO-1 report due on September 30, 2007, employers are not required to resurvey and may use employment data from any one pay period between July and September 2007. Nevertheless, the EEOC encourages employers to resurvey as soon as possible using the new classifi cation system. Employers must resurvey employees under the new classifi cation system for the 2008 reporting year. Even if an employer decides not to resurvey for 2007, it must still report data on the revised EEO-1 form, and new hires should be surveyed according to the new system.
The new EEO-1 reporting system does not yet apply to affi rmative action program reporting required of federal contractors by Executive Order 11246 and enforced by the Offi ce of Federal Contract Compliance Programs. Recognizing the possibility of inconsistent burdens on federal contractors, the OFCCP is reviewing its classifi cation system and may promulgate changes designed to track the new EEOC system.