EEO: Six Key Tips for Staying Out of Trouble

The Federal Communications Commission is increasing its attention to enforcement of its equal employment opportunity (EEO) rules.

Why now? One reason is criticism by advocacy groups of lax enforcement under FCC Julius Chairman Genachowski in the past. Some say the commission’s central focus on broadband deployment is a cause of that. Also, the new license renewal application cycle began June 1.The application requires EEO information for the whole expiring term, and traditionally the FCC focuses on EEO at renewal time. Attention to the items listed below can help stations avoid heartache and FCC sanctions for noncompliance.

1. Know what EEO information is required for license renewal, and assure to keep track of it continuously. That’s key because the renewal application asks about FCC compliance for the whole expiring term.
2. Be prepared for a random FCC audit of station EEO compliance. Here’s a link to the FCC’s most recent audit letter, dated March 29, 2011. Note that it requires some information that is different from what other forms require.
3. When choosing which EEO community outreach initiatives to do every two years, be realistic, and match your activities to the selected categories in advance, not the other way around.
4. Be sure to “churn” your list of referral sources periodically during the license term.
5. After notifying recruitment sources of a vacancy, wait a reasonable time before hiring someone to allow applications to be submitted and reviewed by the station.
6. Stations don't need to recruit for part-time or temporary jobs. But if one of those positions is converted to full time or permanent, recruiting (including contacting referral sources) must be done for it.