Infographics

Is the EEOC pay data dashboard a cost-effective and useful way to evaluate pay equity issues?

July 3, 2024

Substantial reporting burden imposed on companies for little additional information

The EEOC released dashboard information on pay collected in 2017 and 2018 in EEO-1 Component 2 submissions with a stated purpose of allowing companies to compare their compensation situation relative to others in their industry and geography.

The EEOC’s controversial data collection lacked a clear plan for use and did not list any benefits to justify the burden on companies. CRA followed the EEOC’s methodology to summarize the occupation and earnings data from the American Community Survey (ACS), a nationally representative and publicly available survey of over three million people per year, and create similar compensation summaries by gender and industry.

2018 gender pay distribution from the EEOC dashboard
2018 gender pay distribution from the EEOC dashboard

2018 gender pay distribution from the American Community Survey
2018 gender pay distribution from the American Community Survey

The similarity in the gender pay distribution as shown in these charts is striking. It is hard to tell that they came from completely different sources, one of which – the ACS – was already available and used extensively by government agencies, the HR community, consultants, and academics.

The similarities between the ACS and EEOC Dashboard extend to industry comparisons. For example, the charts below show the distribution similarity for the Finance and Insurance Services industry.

2018 gender pay distribution from the EEOC dashboard – Finance and Insurance Services Industry
2018 gender pay distribution from the EEOC dashboard - Finance and Insurance Services Industry

2018 gender pay distribution from the American Community Survey – Finance and Insurance Services Industry
2018 gender pay distribution from the American Community Survey - Finance and Insurance Services Industry

Pay equity is a complex and dynamic issue. Aggregate unadjusted pay gap comparisons, such as those in the EEOC dashboard and reproduced in the charts above, miss key factors impacting compensation, yielding unhelpful conclusions. CRA’s Labor and Employment economists have designed and executed pay equity audits in numerous industries and countries to assess compliance with international, federal, and state employment regulations. Proactive pay equity audits are cost-effective for evaluating compensation practices and mitigating litigation and reputational risk.

Note: This study attempts to make the EEOC pay data and ACS data as comparable as possible but they are not perfectly aligned. For example, the EEOC pay data covers firms with at least 100 employees, while the ACS does not track employer size and respondents working for small employers could not be excluded. However, this study does exclude self employed people. Also, the ACS wage and salary income measure comes as close as possible to the W-2 Box 5 earnings in the EEOC data collection, but may not match exactly.