Annual EEO Report Filing Deadline Set for April 1posted on 3.19.2018
Texas radio and TV stations have an April 1 deadline to place their annual EEO Public File Report in the online station public inspection file and to post the report on the station website, if there is one. TAB’s FCC counsel, Pillsbury Winthrop Shaw Pittman, has issued an advisory on the report.
The annual EEO Public File Report summarizes a radio or TV station employment unit’s (SEU) EEO activities during the previous 12 months. Scott Flick, a co-author of the advisory, said licensees must maintain adequate records to document those activities.
Under the FCC’s EEO Rule, all radio and television SEUs, regardless of staff size, must afford equal opportunity to all qualified persons and practice nondiscrimination in employment. SEUs with five or more full-time employees (“Nonexempt SEUs”) must also comply with the FCC’s three-prong EEO outreach requirements.
Flick said nonexempt SEUs must:
- broadly and inclusively disseminate information about every full-time job opening, except in exigent circumstances
- send notifications of full-time job vacancies to referral organizations that have requested such notification, and
- earn a certain minimum number of EEO credits, based on participation in various non-vacancy-specific outreach initiatives (“Menu Options”) suggested by the FCC, during each of the two-year segments (four segments total) that comprise a station’s eight-year license term.
“These Menu Option initiatives include, for example, sponsoring job fairs, participating in job fairs, and having an internship program,” Flick said. Nonexempt SEUs must prepare and place their Annual EEO Public File Report in the public inspection files and on the websites of all stations comprising the SEU by the anniversary date of the filing deadline for that station’s license renewal application, which is April 1.
For a detailed description of the EEO Rule and practical assistance in preparing a compliance plan, broadcasters can consult Pillsbury’s The FCC’s Equal Employment Opportunity Rules and Policies – A Guide for Broadcasters
Nonexempt Texas TV SEUs should note that they also must electronically file an EEO Mid-Term Report on FCC Form 397 by April 2. Part of that submission includes attaching copies of the SEU’s two most recent Annual EEO Public File Reports to Form 397.
Astute station staff will notice that the actual mid-point of the Texas TV license renewal term is technically April 1, but because that date falls on a weekend, submission of FCC Form 397 may be made by April 2.
Read more about the EEO Mid-Term Report requirements here.
Have a specific question about the FCC’s EEO rules? Contact TAB’s Michael Schneider or call (512) 322-9944.
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