Broadcast Station EEO Audit Announced

Posted on March 31st, 2022 by

On March 21, 2022, the FCC’s Enforcement Bureau announced an EEO Audit of 280 broadcast television and radio stations, giving them until May 5, 2022 to respond to the audit.  The notice and list of stations can be found here.  Double check to see if any of your stations are on it.

This is the first of what is usually two annual EEO audits by the Bureau.  The other one will probably be issued in late summer or early fall.  Stations no longer have to mail documents to the FCC to respond to EEO audits – an upload to the station public file by the deadline is sufficient. Following that, the Bureau staff review the submissions and either ask for more information or issue an “all clear” letter to the station.  Stations on the list are required to post the audit letter, response, and later correspondence in the EEO Audits folder of the public file.

The audit requires locating and submitting a substantial amount of documentation unless a station employment unit is exempt because it has fewer than five full time employees, completed an earlier audit, or because of its status as a religious broadcaster.  Stations should start early to ensure there is enough time to completely respond.

Even if your station is not on the list, now is a good time to cross-check your EEO obligations, record-keeping, and public file reports.  Is your SEU retaining dated records of all job postings/announcements?  Are you periodically evaluating, and if necessary, updating the sources used to recruit candidates for job vacancies?  Can you tell from your records which sources produced interviewees and how many, and then which source produced the interviewee that was ultimately hired?  Do you have documentation of the menu option activities the SEU completed?  Do you know which employees participated in those activities?  For non-exempt stations, all of this and more is required to respond to an EEO audit.