MVPD Annual EEO Program Reports and SIS Responses Due Sept. 30, 2014
By Elizabeth A. Drogula
The FCC’s equal employment opportunity (“EEO”) rules for multi-channel video program distributors (“MVPD”) require MVPD employment units with six or more full-time employees to file an Annual EEO Program Report, FCC Form 396-C. This is an electronic filing that must be submitted to the FCC on or before Sept.30 of each year. The FCC released a Public Notice yesterday to remind MVPDs of this filing deadline, and to identify the employment units that will also be required to submit responses to a Supplemental Investigation Sheet (“SIS”) with their FCC Form 396-C filings.The SIS is an electronic form that will be attached to the FCC Form 396-Cs of the employment units identified in the Public Notice. It has three parts:
Part I of the SIS requires one or more written job descriptions for positions in specified job categories. This year, the FCC has requested that responding employment units submit one written job description for a position in the Sales Workers job category.
Part II of the SIS requires narrative responses to questions about the unit’s EEO program. There are nine questions in Part II of the SIS, of which the FCC typically selects three to be answered in a given year. This year, the FCC has requested that employment units provide answers to the following three questions:
Question 1: Describe the employment unit's efforts to comply with the outreach provisions of 47 C.F.R. Section 76.75(b).
Question 6: Report the findings of the employment unit's analysis of its efforts to recruit, hire and promote in a nondiscriminatory manner and explain any difficulties encountered in implementing its EEO program.
Question 7: Describe the responsibility of each level of the employment unit's management with respect to application and enforcement of its EEO policy and explain the procedure for review and control of managerial and supervisory performance.
Finally, Part III of the SIS requires employment units to submit a copy of their EEO Public File Report for the previous twelve month period.
If you have any questions about the annual FCC Form 396-C filing or responding to the SIS, please contact Liz Drogula.