Monday, April 1 is the deadline for broadcast stations licensed to communities in Indiana to place their Annual EEO Public File Report in their Public Inspection File and post the report on their station website. Under the FCC’s EEO Rule, all radio and television station employment units, regardless of staff size, must afford equal opportunity to all qualified persons and practice nondiscrimination in employment.
In addition, those broadcasters with five or more full-time employees must also comply with the FCC’s three-prong outreach requirements. Specifically, broadcasters 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.
IBA’s Washington, D.C. attorney David Oxenford notes that “stations do not need to file a Mid-Term EEO report. Instead, the FCC will review this year’s report and last year’s report to see if they have any questions – effectively what they did with the Mid-Term report but they just pull the information from your public inspection file instead of making you file another document.
“For radio stations, when you do file your EEO report you need to note whether or not your cluster of stations – your station employment unit – has 11 or more full-time employees. The FCC will only be doing this Mid-Term review of the radio groups with 11 or more full-time employees. But, since every radio cluster with 5 or more full-time employees needs to submit to their public file the Annual EEO Public Inspection File Report, the FCC needs to know which of those companies that did the Public Inspection File Report will be subject to the Mid-Term review. There is a pop-up in the public file for radio stations where you are to report that information as to whether or not you have 11 or more full-time employees.”
