FR 2021-01056

The document under review is an official notice from the Equal Employment Opportunity Commission (EEOC) regarding the continuation of data collection through the State and Local Government Information (EEO-4) reports. This extension, which requires approval from the Office of Management and Budget (OMB), is set to last for an additional three years and will remain unchanged. The EEO-4 data collection is conducted biennially and is mandated for state and local governments with 100 or more employees. The EEOC uses the collected data to investigate discrimination claims and enhance its research efforts.

General Summary

The EEOC aims to extend its information collection practices with state and local governments without making any changes to the current process. The data collected from these entities helps in identifying and addressing potential employment discrimination, which aligns with the EEOC's broader objectives. Interested parties could submit their comments on this proposal until March 22, 2021. In recent years, the EEOC has streamlined the data submission process by introducing electronic filing as the preferred method, thereby simplifying the procedure for government entities.

Significant Issues or Concerns

The document presents a number of issues:

1. Transparency in Cost Calculation: The document states the respondent cost for the data collection process as $4,719,509.02 but does not provide a clear breakdown of how this figure was arrived at. This raises concerns about transparency and potential financial inefficiencies.

2. Data Security Measures: While electronic filing is encouraged, the document fails to detail the security measures in place to protect sensitive information. This omission could lead to concerns about data privacy and the safeguarding of sensitive employee records.

3. Practical Utility and Relevance: The notice solicits public comment on whether the information collection is necessary for EEOC's functions. However, it does not elaborate on how the practical utility of the collected data is assessed, leaving stakeholders uncertain about its necessity and relevance.

4. Outdated Methodology: The estimate for the time required to submit reports is based on a review from 2018. Without further updates or explanations, this may not account for improvements in technology or procedural changes that could affect current processing times.

5. Wage Calculation Assumptions: The basis for determining median hourly wages used to calculate burden hour costs is not explained, questioning the accuracy and fairness of the estimates.

Impact on the Public

The continuation of the EEO-4 data collection directly affects a segment of the public—state and local government entities with large workforces. The efficiency or inefficiency of this process can impact how resources are allocated within these organizations. An effective data collection process ensures less administrative burden, allowing them to focus on providing services to the general public.

Impact on Specific Stakeholders

For specific stakeholders like state and local government HR departments, the streamlining of the report submission process through electronic means may result in operational efficiencies and reduced resource expenditure. However, concerns about cost transparency and security could potentially overshadow these benefits, leading to apprehensions about resource allocation and data protection.

In conclusion, while the extension of the EEO-4 data collection promises continuity in pursuing employment equity, the document could benefit from addressing significant concerns about transparency, security, and process relevance. These enhancements would not only build trust among data providers but also ensure the sustained success of the EEOC's mission.

The Federal Register document from the Equal Employment Opportunity Commission (EEOC) outlines a request for a three-year extension of a data collection initiative known as the State and Local Government Information (EEO-4). Within this document, several financial figures are highlighted concerning the costs related to this data collection process.

Financial Overview

The document states that the respondent cost for this biennial collection is approximately $4,719,509.02. This amount encompasses the expenses borne by state and local governments who are required to gather and submit the necessary data for the EEO-4 reports. It is calculated based on burden hour costs, which factor in the wages of staff involved in the submission process.

Additionally, the federal cost associated with managing and processing these data submissions amounts to $386,609.20 per biennial collection period. This reflects the government's expenses in overseeing the collection, including the administrative support and technological infrastructure needed.

Relation to Identified Issues

The transparency of how these financial amounts are derived is a focal issue identified in the document. Although the document specifies that the burden hour cost per report is $214.77, it lacks detailed explanation of the calculation method used to arrive at the total respondent cost of $4,719,509.02. This absence of detail might raise questions about the clarity and potential efficiency of the expenditure, as stakeholders might be concerned about the implications of such substantial respondent costs.

Another point of concern is the usage of electronic filing systems for submitting EEO-4 Reports. While the document promotes electronic submissions, it does not elaborate on cost-related impacts or the benefits of these technological advancements in terms of reducing respondent costs. With the estimated submission time of 7 hours per reporting unit being based on a 2018 review, there is an implication that these costs may not adequately reflect modern efficiencies gained via technology advancements.

Furthermore, there is a lack of detailed methodology regarding the calculation of burden hour costs based on median hourly wages. The document does not provide in-depth information on how these wage rates are determined, which could lead to scrutiny over whether these calculations are both accurate and fair.

In summary, while the document outlines significant financial figures related to the EEO-4 data collection, the absence of comprehensive explanations concerning the determination and justification of these costs may lead to concerns over transparency and efficiency in the allocation of these funds. Stakeholders might call for greater clarity and justification to ensure that the significant amounts spent are justified, efficient, and necessary.