pay disclosure

Pay Transparency to Current Employees – New Laws Require More Than Job Posting Disclosures

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In 2021, employers had to grapple with a host of new pay transparency requirements across the country, which we previously outlined here.  While most of these concern requirements to provide salary range information to applicants to posted jobs, several require disclosure of salary range information to current employees under certain circumstances.  Employers who have addressed pay range disclosures in job postings are well-advised to also review their practices with respect to current employees to ensure compliance. READ MORE →

EEOC Yanks Its Pay Data Collection Efforts For Future Years

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Yesterday, the EEOC announced that it does not intend to renew its request for authorization to collect employers’ pay data on the EEO-1 form in future years. The announcement comes less than three weeks before the September 30th deadline for employers nationwide to submit massive amounts of pay data for 2017 and 2018 (a deadline that is not impacted by the EEOC’s announcement).

The rollercoaster saga of the EEOC’s pay data collection (which we previously reported on including here, here, here, here, here, here, and here) began over three-and-a-half years ago when the EEOC announced in January 2016 its plan to revise the EEO-1 form to collect pay data (Component 2 data). The revised EEO-1 form requires employers to submit data on employees’ W-2 earnings and hours worked across broad job categories, and broken down by ethnicity, race, and sex. While the EEOC contends that the revised EEO-1 form will allow it to better assess pay discrimination, employers have expressed numerous concerns, including that the form may indicate “false positives,” as the broad EEO-1 job categories are not designed to group employees who perform similar work (as defined by federal and state equal pay and anti-discrimination statutes). READ MORE →