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September 17, 2019 | HR Compliance | Posted by Bob Greene, Senior HR Industry Analyst at Ascentis

Q&A Follow Up Part 2: EEO-1 Component 2 Data Reporting

With the reporting deadline for the newly reinstated EEO-1 Component 2 data just around the corner (September 30, 2019), we’ve recapped the questions submitted during our webinar, The EEO-1 Component 2 Data Reporting Requirement: Are You Ready? in a two-part blog series. Let’s jump in to part two, featuring Q&A on employment types, Component 1 vs. Component 2, and Component 2 reporting methods.

 Leased and Temporary Employees

Q: When you mention leased employees are to be included does this include all temp employees provided by a 3rd party agency?

This pronouncement by the EEOC seems to have generated a fair amount of confusion, but from everything we’ve researched, the rule appears to be no different than the one we’ve been using for decades for Component 1 (traditional) reporting. The payer withholding Social Security tax from the employee is considered the employer who reports for both EEO-1 traditional AND EEO-1 Component 2 reporting. Contractors who are not issued forms W-2 and have no Social Security tax withheld may be excluded. Just be sure to exercise care about your classifications, particularly as we prepare to transition into much more restrictive rules (e.g., California effective 1/1/20) on contractor classification.

Reconciling Component 1 and Component 2 Data Reporting

Q: Does the payroll used for the EEO-1 report and the EEO-1/C2 report need to be the same?

A fair number of questions came in that appeared to anticipate there would be some grand reconciliation of Component 1 (traditional) and Component 2 reporting. We can find no evidence that this will occur. The fact that EEOC/NORC has indicated that the measuring periods need not match, and that Component-1 reporting is “point-in-time” while Component 2 reports aggregated data over the course of a calendar year, appears to rule out any meaningful “reconciliation” of the two.

Component 2 Data Reporting Methods

Q: If we have the data in a format that looks just like the sample form, will we be able to manually type the data in to the EEO website? Or do we have to do the upload?

Employers having a report from their service provided that is in the matrix format illustrated on the NORC website are certainly able to update the site, cell by cell. As we point out in our webinar (now available on-demand), each separate report requires potential update of up to 1,680 separate cells and even the simplest reporter (single-establishment) will be updating at least four such reports. Employers doing multi-establishment reporting may find this an impractical solution.

Q: I have Component 2 completed, but it downloads from our Payroll System only into a PDF and I do not have the program to convert it into a CSV. What should I do?

We suggest going back to your payroll service provider to inquire about a CSV equivalent. If that is unavailable, consider hiring a third party to convert the PDf to .CSV, paying close attention to the parsing process to keep the data valid.

Q: Do employers receive a report with the results once all reports have been submitted?

The NORC site does give the reporter the opportunity to download a copy of the report after entering the date and prior to closing out the year, per the information available on the website.

Ascentis Clients: Support for EEO-1 Component 2 Reporting

Q: Do I understand that this reporting will be available if we have Ascentis HR and Payroll?

Ascentis released our full support for an EEO-1 Component 2 CSV file download over the Labor Day weekend. Clients active on Ascentis HRIS and Payroll for the entirety of the reporting year will find full support for creating this file for you to upload on the NORC site.

Q: Ascentis has a template for the EEOC-1. Does/will Ascentis be creating a template to run a report for EEOC-2 in time for this year’s deadline?

Ascentis held a one-hour clients-only webinar on August 23, 2019 during which we reviewed everything you need to know to generate this new report. The August 23 webinar was recorded and is now available for on-demand review through the Ascentis Communities portal.

In case you missed the live webinar, check out the on-demand recording for more help with your EEO-1 Component 2 Data Reporting.

Bob Greene currently serves as Senior HR Industry Analyst at Ascentis. Bob’s 40 years in the human capital management industry have been spent in practitioner, consultant and vendor/partner roles. As practitioner, he managed payroll for a 5,000-person bank in New Jersey. As consultant, he spent 8 years advising customers in HRMS, and payroll and benefits system design as well as acquisition strategies. Bob also built a strategic HCM advisory practice for Xcelicor (later acquired by Deloitte Consulting.)