EEO-1 Reporting Changes

Major changes in the data collection requirements mandated by the Equal Employment Opportunity Commission (EEOC) are hitting home this year.

The EEO-1 report that previously was due by the end of September of each year is now due by the end of March of each year.  In addition, beyond the employment data by the ten EEO categories (Upper Management, Middle to Lower Management, Professionals, etc.) that has been required in the past, employers must now provide 2018 pay data and hours worked tabulated by those same EEO categories for all U.S. based employees.  The data is to be provided for a payroll period falling in the last calendar quarter of the previous year.

Who must file EEO-1 reports? All companies that meet the following criteria are required to file the EEO-1 report annually:

  1. Subject to Title VII of the Civil Rights Act of 1964, as amended, with 100 or more employees; or
  2. Subject to Title VII of the Civil Rights Act of 1964, as amended, with fewer than 100 employees if the company is owned by or corporately affiliated with another company and the entire enterprise employs a total of 100 or more employees; or
  3. Federal government prime contractors or first-tier subcontractors subject to Executive Order 11246, as amended, with 50 or more employees and a prime contract or first-tier subcontract amounting to $50,000 or more.

This includes non-profit as well as for-profit organizations.  It excludes federal, state and local government employers,  schools and universities, as well as a few other categories, which are required to file similar reports but not the EEO-1s.

The addition of the pay data requirement is intended to improve EEOC investigations into pay discrimination based on gender, race and ethnicity.

This additional reporting requirement was scheduled to be due March 31, 2019 along with the regular employment data.  However, due to legal challenges and other delays, the employment data is not due until the end of May and the pay data until the end of September of this year.

As I indicated in a previous blog, I do not see how the EEOC can reach conclusions regarding pay equity based on the data collected, as the categories to be used (i.e. the eight EEO1 categories, covering all jobs from top management to entry-level laborers) are too broad for comparison.

Gigs, Freelancing and ProBono Work in “Retirement”


I have now been “retired” from my full-time professional job for several years, and have had the opportunity to spend my time in a much different way.  I have bought into the idea of having a “portfolio” of endeavors, some which pay for my time and others which do not.

I was introduced to this new approach through Encore NEO, a non-profit focused on assisting individuals 50 years and older to “craft meaningful careers and
satisfying lifestyles for the second halves of their lives”.

In my case, my “portfolio” consists of the following:

  • traditional part-time employment (around 20 hrs. per week in retail customer service jobs)
  • volunteering (on the Board of Encore NEO)
  • freelance “gigs” (as an HR consultant)

I still have free time to enjoy golf, hiking, traveling, and reading,  with a little time left over for chores (laundry, cleaning, groceries, etc.).

Being old enough for Medicare coverage (over 65), I do not have to worry about health insurance;  that eliminates the need to work full-time, which, admittedly, makes this arrangement possible.

My wife and I sold our house of 32 years in 2018 and downsized into a condo.  Part of the process was to rid ourselves of unnecessary “stuff” (which took three years), things we either hardly ever used or would not need in our new living arrangement (condo living eliminates the yard work and external home maintenance).  This has simplified our lives considerably, freeing up my time for the “portfolio” endeavors.

I am finding part-time work to be very enjoyable.  As opposed to my original full-time HR and consulting career, I do not bring the job home with me. It is less stressful while still providing a feeling of accomplishment and value in my contribution to the customers and the employer. I have also been fortunate to find the part-time work close to home, eliminating the time I used to spend sitting in traffic going to and from the office.

A further new endeavor for me is this blog, which has led to writing a book.  I joined the Legacy Writers group sponsored by Encore NEO and the Geauga County Public Library, and learned how to start a blog and how to blog to a book. And it’s free! This has proven to be an inspiring venture and a whole lot of fun.

Maybe best of all, I am free to modify my “portfolio” as conditions and my interests change.  I am not relying on any of the pieces to maintain my lifestyle, thanks to downsizing and simplifying.

Getting old has its benefits.



Equal Pay For Equal Work?…..the pay gap for women in the U.S.



A recent survey of the pay gap by gender from the Pew Research Center indicates that average pay for females has remained at around 82% of the average for males, holding steady for the last 15 years or so.  Younger workers in the U.S. have a significantly lower gender pay gap than older workers (89%), but, as suggested in the Pew study, this may be due to older workers holding higher paying jobs.  If so, the gender pay gap for the younger workers could continue to widen as they age.

How does the U.S. rank in the global economy? A recent issue of The Economist (February 2018) indicated that Canada is ahead of the U.S. in the index of environment for working women; in fact, the U.S. is below the average for the 29 countries listed. So, not so well.

There is a lot written on the perceived reasons for the persistent gap.  From my perspective, after 40+ years of HR experience, it is mainly due to the difference in the mix of jobs held by women versus men.  As noted in the Pew study mentioned above….

Even though women have increased their presence in higher-paying occupations traditionally dominated by men, such as professional and managerial positions, women as a whole continue to be overrepresented in lower-paying occupations, such as office/clerical and paraprofessional.

Given that the market drives pay rates based on the value of the job to the employer (“demand”), as well as the availability of qualified candidates (“supply”), one path to narrowing the pay gap is to improve the “supply” of women for the higher paying jobs, which happens through training and education.

But is it also a matter of preference; do women prefer certain jobs over others? One example is the persistent lack of female candidates for engineering jobs, which tend to be higher paying professional jobs.  Another example is the skilled trades (machinists, electricians, carpenters, etc.).

Some economists have speculated that the lower average pay for women is due to their lifestyle choices; choosing to have and raise children being the most impactful choice. These economists reason that employers are not too keen on providing women the time off or reduced work hours/flexible schedules needed to allow them to stay employed and also spend time with their children.  As a result, their careers are interrupted and pay progression moves back rather than forward.

The U.S. DOL is moving to collect pay data from all employers who are required to complete the annual EEO-1 report in order to monitor employer pay practices that may indicate discriminatory treatment based on gender. I do not see how they can reach conclusions regarding pay equity based on the data collected, as the categories to be used are too broad for comparison (i.e. the eight EEO1 categories, covering all jobs from top management to entry-level laborers).  See my more recent blog on this matter.

It is my belief that the pay gap will continue to exist for many more years, but not due to discriminatory practices.  I believe that it will be market-driven forces, i.e. supply and demand, that will narrow the gap, which is a slow process.


A recent article, “Pay Equity: Having Kids Curbs Women’s Earnings” (April 14, 2019, Janet Paskin, Bloomberg News) points out that there is little if any gender gap at the beginning of the career path; the gap widens once women have their first child. For women who do not have children, the pay gap is much smaller.  It’s clear that lifestyle choices affect the gender pay gap.