As we reported earlier today, OFCCP has announced proposed regulations to satisfy President Obama’s mandate that contractors submit detailed pay data. The NPRM will be officially published in the Federal Register this Friday with a 90 day public comment period after that.

As proposed, the data collection tool, called the Equal Pay Report (EPR) in the NPRM, is an annual supplement to the EEO-1 Report.  The NPRM proposes the following:

• Annual report to be filed in the first quarter of every year

• Required for Employers with 100 or more employees

• To be filed separately for each establishment

• Report W-2 earnings for all employees aggregated by EEO-1 category – so employers must report on total comp, as opposed to base comp like most employers include in AAP submissions to OFCCP

• Report aggregated hours for all non-exempt employees by EEO-1 category – and for all exempt employees if tracked by the employer

We continue to digest the 150 pages of the NPRM and will continue to post detailed analyses of the proposed Equal Pay Report and accompanying regulations.  Stay tuned.