Overview of 2015 EEO Random Audits
On June 18, 2015, the Federal Communications Commission released Public Notice DA 15-718, announcing the mailing of its second round of Equal Employment Opportunity (EEO) audit letters for 2015. The audit notices were mailed on June 12, 2015, to a randomly selected group of radio broadcast licensees across the United States.
Pursuant to 47 C.F.R. § 73.2080(f)(4), the Commission audits approximately five percent of all radio and television stations on an annual basis to evaluate compliance with its EEO rules. This second mailing follows the initial 2015 audit cycle announced via Public Notice DA 15-197 on February 11, 2015.
- Audit letters mailed: June 12, 2015
- Public notice release date: June 18, 2015
- Response deadline: July 27, 2015
- Regulatory authority: 47 C.F.R. § 73.2080(f)(4)
Audit Requirements and Requested Documentation
The audit letters require employment units with five or more full-time employees (defined as regularly scheduled for 30 hours or more per week) to provide extensive recruitment and compliance records. Units must supply copies of their two most recent EEO public file reports, list the dates of all full-time hires, and document the specific recruitment sources used for each vacancy.
Licensees must also provide documentation for broad recruitment initiatives completed during the two-year period, such as job fairs, mentoring programs, or staff training. Depending on unit size and market population (whether 250,000 or greater), stations must verify whether they were required to complete two or four initiatives under 47 C.F.R. § 73.2080(c)(2) and (e)(3).
All units, regardless of employee headcount, are required to disclose any pending or resolved discrimination complaints filed against the station during the current license term before any administrative, judicial, or local body.
- Two most recent EEO public file reports, including full-time hire dates
- Dated copies of position advertisements, job notices, and referral source records
- Total interviewee counts and corresponding referral sources for all vacancies
- Documentation of two or four broad recruitment initiatives
- Disclosure of all employment discrimination complaints during the license term
- Narrative descriptions of management EEO responsibilities, recruitment analyses, and periodic reviews of employment practices
Website Posting and Public Inspection File Rules
The Commission reminded stations with five or more full-time employees of their obligation under 47 C.F.R. § 73.2080(c)(6) to post their most recent EEO public file report on their website by the required public file deadline. If a station unit lacks its own website but has a corporate parent site, the report must be linked on either the unit's page or the general corporate site. Failure to comply is a rule violation subject to sanctions and monetary forfeitures.
In accordance with 47 C.F.R. §§ 73.3526(e)(10) for commercial stations and 73.3527(e)(11) for noncommercial educational stations, licensees must place a copy of the audit letter and their submitted response into their station public inspection file. Licensees are instructed to exclude personal identifying information, such as social security numbers and home addresses, from their submissions.
- Mandatory website posting under 47 C.F.R. § 73.2080(c)(6)
- Inclusion of audit letters and filings in the public inspection file
- Exclusion of personally identifiable information from submitted records
Submission Procedures and Contact Information
Audit responses must be certified by an officer, partner, or principal of the licensee and received by the Commission by July 27, 2015. Filings must be addressed directly to the EEO Staff within the Media Bureau's Policy Division and should not be sent to the FCC Secretary's office.
Stations that were audited on June 26, 2013, or during 2014 or 2015, or those whose license renewal applications were granted by final order within the past 18 months, may qualify for an exemption upon contacting Commission staff.
Agency inquiries regarding the audit notice may be directed to Media Bureau Assistant Chief Lewis C. Pulley at (202) 418-1450, or News Media Contact Janice Wise at (202) 418-8165.
- Mailing Address: EEO Staff, Policy Division, Media Bureau, FCC, 445 12th Street, S.W., Washington, DC 20554
- Media Bureau Contact: Lewis Pulley at (202) 418-1450
- News Media Contact: Janice Wise at (202) 418-8165