On July 1, 2019, the Equal Employment Opportunity Commission (EEOC) updated the Component 2 filing site with answers to frequently asked questions (FAQs) and other materials to assist filers with the submission of Component 2 data. Here are a few highlights from the new materials.
As previously noted, employers must file 2017 and 2018 Component 2 compensation data by September 30, 2019. Employee Thresholds
Employers, including federal contractors, are required to submit Component 2 compensation data for 2017 if they have 100 or more employees during the 2017 workforce snapshot period. Employers, including federal contractors, are required to submit Component 2 compensation data for 2018 if they have 100 or more employees during the 2018 workforce snapshot period. Federal contractors with 50-99 employees are not required to report Component 2 compensation data. Snapshot Period
The workforce snapshot period continues to be an employer-selected pay period between October 1 and December 31 of the reporting year. The only employees whose compensation and hours-worked data must be reported are those full- and part-time employees who were on the employer's payroll during the workforce snapshot period. Employers are permitted to choose a different workforce snapshot period for reporting Component 2 data for 2017 and 2018. In addition, employers are not obligated to choose a pay period when it has 100 or more employees. As a result, employers with workforces that fluctuated above and below the 100-employee threshold in October through December may choose a workforce snapshot period where the employee population fell below 100 employees and avoid the Component 2 filing requirement. In many circumstances, it is favorable for employers to use the same snapshot date as was used for the 2017 and 2018 Component 1 filings. Compensation Bands
To identify the compensation band in which to count an employee, employers are to use "Box 1 - Wages, tips, other compensation" of Internal Revenue Service (IRS) Form W-2 as the measure of pay for Component 2. Employers are required to report the W-2 Box 1 income only for the selected workforce snapshot period employees. Employers may not use...