Reporting Problems for Private Employers

Preceding sections have described Federal EEO pro-
grams, the legal basis and rationale for key paperwork
requirements, and the organizational relationships among
EEO agencies. In this section, the Commission on Federal
Paperwork addresses the major reporting and record-
keeping problems of private employers. Among the topics
discussed are the following:

• Government contractors must use cumbersome
and costly methods to obtain certifications of EEO
compliance from their subcontractors.

• Reporting requirements vary from agency to
agency. This lack of uniformity and consistency is
most acute for diverse companies that must report
to more than one Federal agency.

Compliance reviews by Federal agencies are not
well enough coordinated. Some employers or
facilities are subjected to repetitive reviews (even in
the absence of complaints) while others escape
scrutiny almost completely.

The interpretation of guidelines prepared by
Federal agencies for affirmative action plans is
inconsistent.

• Federal agencies fail to distinguish, as far as
repetitive paperwork is concerned, between com-
panies with favorable compliance records and
those with compliance problems.

• Government lacks machinery to work with employ-
ers to improve results, coordinate enforcement
activities, and cut red tape.

For each of these problem areas, this Commission has
developed recommendations.

Cost to Employers

The Nation's business establishments covered by EEO spend millions of dollars annually on EEO reporting and recordkeeping activities. Using conservative estimates, employer costs for the EEO-1 survey exceed $12 million annually. Yet, the EEO-1 form appears to be the least burdensome of the Federal EEO reporting requirements.

'Universe of 80,000 employers completing 160,000 forms (5 hours per form) at $15.00.

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The total costs to prepare and maintain Affirmative Action Plans vary greatly among employers, and cannot be estimated with confidence due to the many variables that exist. The cost will vary between respondents on the basis of several factors, including size and diversity of the workforce, number of reporting facilities within a company, number of agencies to which respondents report, and discretionary requirements of the compliance officer. Several major corporations were contacted and queried as to their total cost for EEO reporting and recordkeeping. One major corporation, with sales in excess of $2 billion annually, reported its cost for complying with EEO regulations was $11,640. Another corporation, with sales in excess of $550 million, reported cost for EEO compliance to be $87,150. A third corporation, with sales of about $40 million, reported $5,000 in costs; a fourth corporation, with approximately $867 million in sales, reports its total annual EEO costs are $73,000. These wide ranges illustrate the problems of deriving a firm figure on the cost associated with EEO requirements. Figure 2 illustrates the costs reported to the Commission for EEO reporting.

Paperwork for Paperwork's Sake

Employers claim that the paperwork burden created by EEO has obscured the true objectives of EEO. Many employers have stated that there is more concern expressed by Federal representatives about the various EEO forms than is expressed about the respondents' results.

For example, corporations responded positively to the need for Affirmative Action Plans. They pointed out that the Plans are helpful in evaluating their total workforce and for purposes of both short and long range planning. They responded negatively, however, to the formats required by the Federal Government. Many employers felt that the EEO-1 report required by EEOC and the statistical portion of the AAP were requests for the same information, but in different formats; in fact, the information in AAP's is far more detailed. Employers were unanimous in their feelings that too little attention was placed on the results of their affirmative action programs and too much on the form.

One association of private employers stated, "one gets the impression that many officers of these (compliance) agencies are a good deal more interested in paper than in people, in process than in results."