New I-9 Form
The new I-9 was designed to reduce errors such as:
- Validations on certain fields to ensure information is entered correctly;
- Drop-down lists and calendars;
- Embedded instructions for completing each field;
- Buttons that will allow users to access the instructions electronically, print the form and clear the form to start over;
- Additional spaces to enter multiple preparers and translators; and
- Separate instructions from the form. Employers are still required to present the instructions to the employee completing the form.
Employers completing the Form I-9 will still need to print the form, obtain handwritten signatures, and file and monitor for any re-verifications and updates.
New EEO and Pay Reporting Requirements – Pay Data will be Required
The Equal Employment Opportunity Commission (EEOC) has released an updated EEO-1 reporting form, which will require covered employers to provide employee pay data beginning in March 2018. The new requirement is intended to improve EEOC investigations into pay discrimination based on gender, race and ethnicity.
Private employers with 100 or more employees and federal contractors with 50 or more employees must complete an EEO-1 report each year. The new information must be provided in the 2017 form, and to give employers time to collect that data. The deadline for 2017 will be extended by six months to March 31, 2018.
“Collecting pay data is a significant step forward in addressing discriminatory pay practices,” said EEOC Chair Jenny Yang. “This information will assist employers in evaluating their pay practices to prevent pay discrimination and strengthen enforcement of our federal anti-discrimination laws,” she said in a press statement.
What Employers Should Do Now to Prepare
- Consider under supervision of legal counsel conducting a self-audit to determine if there appear to be any pay disparities.
- Assess if any disparities are caused by legitimate business factors, such as tenure or education, and speak with counsel regarding same.
- Address and remedy non-defensible pay disparities.
Employers should also take the following steps to gather the new data required:
- Assess HRIS and payroll systems to ensure generation of the requisite reports.
- Meet with outside vendors to ensure holistic understanding of the new requirements.
- Identify or develop policies that explain how employees earn overtime, bonuses, commissions, and other components of W-2 box 1 wages.
- Put systems in place to readily retrieve data regarding benefits choices employees make, because these choices can significantly affect W-2 income.
- Identify job titles in each of the 10 EE0-1 job categories and analyze job descriptions to ensure they are accurate and will support pay decisions that reflect different job responsibilities.
HROIC is here to help organizations maintain compliance and plan ahead to navigate these new regulations. If you have any questions, please do not hesitate to reach out to firstname.lastname@example.org