Evaluation of Compensation Data Collected Through the EEO-1 Form (2023) / Chapter Skim
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The initial phase of EEOC investigations may include analysis using the suite of data known as EEO.1 Particular EEO data collections differ by employer type and filing requirements. The EEO-1 is a mandatory form completed by private employers with 100 or more employees.
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The panel comprised economists, sociologists, statisticians, survey methodologists, lawyers, and employer advisors with expertise in measuring data quality, pay gaps, pay discrimination, and pay equity. Several panel members had previously used EEO data in their own research, and two had served on the 2012 National Research Council panel that reviewed EEO-1 data.
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The collection was paused in 2017 and resumed by court order in 2019. To understand how these unique experiences may have contributed to data quality, the panel reviewed the 2013 National Research Council Report, the 2015 Sage Computing report, and the 2016 EEOC information collection request and accompanying instruments.
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. The panel also conducted an exemplar analysis of Component 2 data as might be done by EEOC intake staff, guided by a previously published EEOC report on the tech sector of Silicon Valley (see Chapter 7)
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The panel found numerous and varied data issues in the 2017–2018 Component 2 collection. Figure S-1 provides a high-level summary of the panel's estimates of various key dimensions of data quality for the 2018 Component 2 data: coverage, unit response rates, missing data, and extreme values.
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Firm and establishment identifiers in the Component 2 data are neither consistent nor unique, which impedes trend analysis and data quality assessment. CONCLUSION 4-2: The 2017–2018 Component 2 data have inconsis tent and non-unique firm and establishment identifiers, which impede the maintenance of the master list, trend analysis over time, and data quality checking possible when merging by identifiers.
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Using established, improved meth ods, other federal agencies have demonstrated that individual-level pay data can substantially reduce respondent burden, increase precision in estimating pay gaps, and protect confidentiality. The Bureau of Labor Statistics' Occupational Employment and Wage Statistics collection is an example.
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Appropriate Use As described above, the panel found numerous data errors and measurement concerns in the 2017–2018 Component 2 data. The panel found that these issues preclude certain analyses, such as examining specific firms or establishments expected but not found in the Component 2 data, or examining firms or establishments with missing or problematic data.
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CONCLUSION 7-4: The 2017–2018 Component 2 data are unsuitable for direct determinations of bias or reasonable cause for enforcement purposes. Necessary Short-Term Improvements From these conclusions, the panel identified recommendations to improve future Component 2 data collections.
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However, there are preferred ways to protect confidentiality that do not prevent authorized users from matching records and thereby assessing data quality and trends over time. RECOMMENDATION 4-3: EEOC should use consistent and unique firm and establishment identifiers, facilitating data merges and data checking.
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Filtering the data on number of employees by removing a small amount of data can address some, but not all, issues. RECOMMENDATION 5-1: Before 2017–2018 Component 2 data are used to assist initial investigations of charges, for employer self assessment, or for research on pay differences more generally, the data should be carefully reviewed and cleaned.
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As stated in Conclusion 3-2, the panel found that current pay bands are simply too wide to be useful in many situations. RECOMMENDATION 3-4: If EEOC continues to collect pay data in bands, narrower pay bands should be adopted, and the number of
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The panel understands that EEOC is assessing the measurement of race/ethnicity, and preliminary results indicate the need to determine a method to appropriately count persons of more than one race. As discussed in Chapters 2 and 3, the 2000 Equal Opportunity Survey conducted by the Office of Federal Contract Compliance Programs collected pay data using the combined measurement form of the federal race/ethnicity standard.
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EEOC's job categories are neither directly comparable to other federal occupational data nor sufficiently detailed for analysis of similarly situated employees. The federal Standard Occupational Classification (SOC)
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To do this robustly while minimizing respondent burden, other federal data collections measuring pay of these groups, such as the American Community Survey, may be instructive. The federal government collects employment-related data from employers through several federal statistical agencies.
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EEOC could consider designating its Office of Enterprise Data and Analytics as a federal statistical unit to collect, report, and protect data in anonymized for mat for research purposes (including employer self-assessment) , while targeted investigations for enforcement purposes proceed as a separate data activity.
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