Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant

As a Senior HR Consultant at Berkshire Associates, with over 27 years of experience in the industry, Cindy Karrow, SPHR, SHRM-SCP is recognized as a leading affirmative action compliance expert. She specializes in developing affirmative action programs, educating company executives, acting as company liaison with the OFCCP, and delivering customized training
Find me on:

Recent Posts

EEO-1 Component 2 Update

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on June 7 2019

The EEOC sent out an email to company contacts on June 3. It was short but informative. The agency re-emphasized the requirement to file Component 2—the salary portion of the EEO-1 - for calendar year 2017 and 2018 and that the report was due by September 30, 2019. Remember Component 2 is only required for companies with 100 or more employees. 

Does Providing Pell Grants Make Universities a Federal Contractor? OFCCP’s First Opinion Letter

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on June 7 2019

The Office of Federal Contract Compliance Programs recently issued the agency’s first opinion letter, as promised by Directive 2018-08. Opinion letters are to serve as guidance on specific topics responding to helpdesk inquiries or direct requests for opinion letters. These letters do not change laws, regulations, or OFCCP policy and do not provide legal advice.

EEOC on Target to Collect Component 2 Data Beginning July 15, 2019

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on May 31 2019

EEOC is moving quickly toward implementing the data collection for Component 2 of the EEO-1 report. The agency submitted one of the required periodic updates to Judge Tanya Chutkan on May 24, 2019. The report details their progress with their outsource vendor, NORC, for Component 2 of the EEO-1 report—since awarding the contract on May 1, 2019. The University of Chicago’s National Opinion Research Center, or NORC, is an independent research institution that delivers reliable data and rigorous analysis according to their website. NORC has been working in the field of social science and public opinion research since 1941.

Hot News About EEO-1 Pay Data Submission—Due September 30th

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on May 3 2019

The EEOC announced that it intends to collect pay data and hours worked (Component 2) for 2017 and 2018. This news settles the question that has been looming for weeks about what year(s) of pay data would be collected

Pay data refers to the amount paid on an employee’s W2 form in Box 1. Hours worked are the actual hours worked for employees reported in the data. Remember the EEO-1 is filed using a snapshot of the employee population for one pay period between October 1 and December 31 of the EEO-1 year-to-be-filed. Using employees from the snapshot, the pay and hours worked should be filed for the entire year, through December 31 of 2017 and 2018. 

EEO-1 Pay Data Collection Update

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on April 4 2019

EEOC responded to the Court’s questions about its ability to collect Component 2 of the EEO-1 report on April 3, 2019. Read the full response here. The EEOC’s response is summarized below:  

Update for the 2018 EEO-1 Filing

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on February 1 2019

Today the EEOC announced that the website used for filing the EEO-1s will be open in early March. The delay in opening the website is due to the partial government shutdown that affected the EEOC.

Preparing for the 2018 EEO-1 Filing Season

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on January 18 2019

When I signed up to write this blog I thought we would all be preparing for the 2018 EEO-1 filing season. Instead, the EEOC is closed during the partial federal government shutdown. Therefore, we do not have any new news about the filing. However, we have some suggestions as you prepare for filing the 2018 reports after the EEO-1 website is up and running again.

Another One Bites the Dust—Say Goodbye to 2018

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on December 21 2018

2018 was a very busy year for federal contractors. Before we ring in 2019, let’s take a stroll through some of the highlights and what can be done to prepare for another busy year.

OFCCP Encourages Development of Functional AAPs

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on September 14 2018

OFCCP demonstrated they are listening to federal contractors about the way businesses operate in the current environment. For many contractors, business does not operate out of a single establishment address but from a number of work spaces, including company owned or leased establishments, shared work spaces, client locations, and home offices. Business functions are spread among multiple physical locations, and developing an AAP for each location does not provide leaders with an effective affirmative action analysis for their area of responsibility. Additionally, a single business location may house multiple functions which makes it nearly impossible to provide a meaningful analysis or assign responsibility when the functions are grouped together. 

More CSAL letters on the way!

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on September 7 2018

Surprise! OFCCP announced today (September 7, 2018) that it just mailed out 750 additional Corporate Scheduling Announcement (CSAL) letters to contractor establishments. This list is a supplement to the previously issued list from March 19, 2018.