Component 2 Filings

It's crunch time for your Component 2 Filing. Here's what you probably haven't heard:
  • All employers with 100 or more employees are under a Federal Court Order to file their Component 2 data by September 30th. Federal contractors with 50-99 employees get a pass on this.
  • The Joint Reporting Committee will not be granting extensions.
  • The EEOC and Federal Judge have reached an agreement to accept a response rate of 75%. If they don't reach that rate by September 30th, the portal must remain open until they reach 75%.
  • The Justice Department filed an appeal – but not a stay – so the deadline is firm, but this will likely result in litigation for years.
  • The portal is entirely separate from the Joint Reporting Committee's portal used for filing your EEO-1 report. And there is no intention to compare your EEO-1 Reports for 2017 and 2018 to the Component 2 data you filed for 2017 and 2018.  So, that's one less thing to worry about. The dates don't even need to be the same. Since you are using W-2 data, using the last payroll of each year seems to make the most sense.
  • Since it is a separate portal – your data is not there. You need to log in and get a new password and start from scratch at the National Opinion Research Center's (NORC) website.
  • Before you start, be sure you know if you are a federal contractor or subcontractor, and if you are “affiliated through common ownership and/or centralized management with other entities in an enterprise with a total employment of 100 or more.”
  • If you are filing manually:
    • Don't waste time putting your data onto sample worksheets. Remember there are 12 pay bands and 10 EEO Categories – so 120 rows of data. And there are 14 gender/race/ethnicity columns for each band in each EEO Category. Don't try printing the forms and putting your data into 1,680 different boxes. Just get your spreadsheet lined up on one computer, get on the website and enter it online.
    • You'll see a separate sheet for each EEO Category, one for your headcounts by band, and then for hours worked by band. So, once you get online, you'll just see 12 bands and 14 gender/race/ethnicities at a time. You need to save each of the spreadsheets before you move on to the next form. There are 20 screens and they highlight the cell you are in, so that helps.
    • Employers have been using 1.1 and 1.2 for management for many years now and ending with Category 9 for Service Workers. You won't find that with Component 2. They went from 1 to 10. So, don't be surprised when you look at a screen and see 3 = Professionals or 7 = Craft Workers.
    • If you have sites under 50 – you can choose Type 6 and just enter the total employee count, but then you must manually complete a consolidated report. If you enter the data in Type 8 – it will upload to the consolidated report. Pros and cons each way, but at least the data will match if you use Type 8.
  • If you are uploading your data, (highly recommended!), you'll be coding your EEO Categories from 1 to10, your race/ethnicity/gender from A to N, and your salary bands from 1 to 12.
  • If you have non-binary employees, you can report them in the comments section. (See the FAQs)
  • You are not inputting or uploading anyone's actual pay. You are assigning everyone a pay band. You are entering/uploading your headcounts for each pay band within each EEO Category. And you are entering/uploading hours worked. That's it. No dollars anywhere. But you need the Box 1 dollars to assign the pay band.
  • Remember there are a lot of deductions before you get to Box 1, and people are hired throughout the year, so don't be surprised if you have a management person in a low pay band. That's why you are also entering the hours worked.
  • When you enter your payroll dates, it cannot be the whole year or just one day. It needs to cover at least 7 days, so if you are using year-end data, just use 12/24 to 12/31 each year.
  • If you're still reading this – don't put off filing Component 2 any longer. And if you have a question, check the FAQs first. If the answer is not there – call and wait for a living, breathing person. If you leave a message or send an email – it can take over 8 days to get a response.

Good Luck! And please track your hours. Several organizations, including ours, are collecting and reporting burden hours to the Office of Management and Budget (OMB). Hopefully, we can make sure this is the first and last time we need to file Component 2. There are certainly other, better ways to ensure equal pay and better ways to make EEO policy.

Article submitted by Judy Julius, Owner/Consultant, EEO Consulting