Supplemental materials for LEAP 2025 session Structuring Pay with Confidence: Transparency, Equity and Audits
While HR professionals are likely aware of the rising trend and growth of pay transparency laws, pay equity laws are rising as well. Joanna Colosimo, vice president of workforce equity and compliance strategy at DCI Consulting, dug into this issue during a session at SHRM’s annual conference this past June. She informed HR departments that they must analyze the data before they submit it to federal agencies. But even if your company isn’t required to submit pay information, she says companies should consider performing pay equity analyses.
It’s no surprise that California requires private employers with 100 or more employees to submit an annual pay data report. This includes information on employee compensation and hours worked by job category, race, ethnicity and sex.
“It’s a heavy lift just to get the data they want before you submit it,” says Colosimo.
Over in Illinois, the state’s Department of Labor also requires private employers with more than 100 employees in the state to submit an annual pay data report. This report includes information on the gender, race and ethnicity of employees, as well as their wages.
“In Illinois, you’re giving social security numbers, race, gender, etc. They’re going to do something with it,” Colosimo says. “You don’t want to go to your CEO and say, ‘We submitted this.’ Before you turn it over, you need to tell your teams what’s in that data.”
These are just two examples of a rising trend. Colosimo says that regardless of who is elected president this November, this is a bipartisan trend, and companies should be prepared no matter what happens.
The EEOC’s Strategic Enforcement Plan (SEP) for fiscal years 2024–2028 highlights advancing equal pay as one of its priorities. And a recent EEOC case reminds employers that discriminatory pay practices can exist against male and white employees. For these reasons, companies may want to start preparing meaningful pay equity analyses. Colosimo offers advice on where to start.
Best practice: Implement pay policies that are structured and consistent.
Interested in joining HR Employment Law Advisor? For a limited time, LEAP 2025 attendees can get an annual membership at 30% off at https://www.hremploymentlawadvisor.com/leap30.
