Susan Gross Sholinsky, Peter Stein Quoted in "Hack Your EEO-1 Report: A Guide to Employee Data Reporting"

Employers dodged a bullet this year when the White House blocked looming EEO-1 compensation reporting requirements, but the survey's other reporting responsibilities remain (for businesses with at least 100 employees and certain federal contractors). And we’re well into the “snapshot period.”

You don’t actually have to file the form until March 31. And yes, I know you’ve got open enrollment and a million other things to worry about right now. But it’s only going to get worse from here on out: the new, later filing deadline puts it right in the middle of Affordable Care Act reporting deadlines, W2 filing requirements and more. Lucky you. …

And when you do ask employees for this info, be sure that your forms meet the U.S. Equal Employment Opportunity Commission’s (EEOC) requirements. The agency has strict rules about what can and cannot be on the form, but offers sample forms to help. It’s also important to make clear that providing this info is voluntary and that it won’t be used in any employment-related decisions, say attorneys at Epstein Becker & Green (EBG). And ensure that the collected information is directed to HR — not to the individual’s supervisor or manager, Susan Gross Sholinsky and Peter Stein recommended.

But what happens if the snapshot period is closing and you can’t get everyone to complete the survey? “If the employee does not complete the survey, you may take the information from any applicable existing employment records, and if none exist, make a best guess based on a visual observation of the employee,” Sholinsky and Stein said.