PO Box 45558
Phoenix, AZ 85016
Dianne Post, Attorney
602 271 9019
19 July 2016
EEOC Comments on Proposed Rule Changes: Employer Information Report (EEO-1)
Yes, the EEOC should amend its rules to include gathering summary pay data from employers, including federal contractors, with more than 100 employees.
The gender pay gap is a problem internationally. No country has closed the gap and only 14 countries have closed more than 80% of it (Global Gender Gap 2014). Only by gathering such data and using it for analytical purposes can we hope to achieve equality.
In the U.S. in 2012, the median income for women was $15,000 and men $20,200. For full-time year-round earners, it was women $30,000 and men $33,592 (Legal Momentum).
Education seemed to increase rather than decrease the gap:
Women $30,000 Men $33,592
Not HS Grad:
Women $17,300 Men $23,000
HS Grad, no college:
Women $23,000 Men $29,000
AA degree only:
Women $28,000 Men $35,000
BA/S degree only:
Women $42,000 Men $50,000
In 2015, men’s earnings grew at twice the rate of women’s. The median weekly earnings for full-time male workers were $889 in the third quarter. That’s a 2.2% increase from a year earlier. Full-time female workers’ earnings were $721, up 0.8% from a year earlier. The later data marked the third straight quarter that the increase in male earnings was at least double that of female workers. As a result, women who work full time earned 81.1 cents for every dollar a man earned from July through September. That’s down more than a penny from a year earlier.
Since the Great Recession, men have seen increasing pay in higher-wage, professional fields. The median weekly pay for men working full time in professional jobs – engineers, lawyers and teachers – was $1,345 in the third quarter, up 7.4% from a year earlier. Similar women earned $970 a week, a 2.2% increase from a year earlier (US Gender Pay Gap is Now Even Wider, Eric Morath, Wall Street Journal, 21 October 2015).
This is a global problem as well as a local one.
In every region in the world, women do 2.5 times as much work as men. Over all, three-fourths of men and one-half of women are in the work force. Yet, two-thirds of women in family businesses do not get paid. Women receive 24% less pay, thus cascading into lesser pensions as women age (UN Progress of World’s Women 2015-2016).
The world is both wealthier and more unequal today than at any point since World War II. The richest 1% of the world’s population now owns about 40% of the world’s assets, while the bottom half owns no more than 1%. To create equal work for women we need formal policies, paid work, and labor-saving equipment. We also need gender-responsive social policies such as pensions, health care, and money transfers along with rights-based macroeconomic policies – trade, tax policy, debt restructuring, deficit spending, and gender budgeting (UN Progress).
Cross-national comparisons repeatedly find that the U.S. has a higher relative poverty measure (RPM) than comparable countries. In the late 2000s, the U.S. had a 17.0 RPM, which was the fourth highest among the OECD’s 34 member nations, 6.0 points above the 11.0 OECD average, and exceeded only by Chile (18.0), Israel (20.0), and Mexico (21.0). (OECD October 2015).
U.S. single parents are the worst off compared to 16 high-income countries. U.S. single parents have above average employment rates, an exceptionally high share of full-time as opposed to part-time employment, and high rates of low-wage employment. The majority of minimum wage earners are women, and while working mothers earn two-thirds of household earnings, a 21% wage gap between women and men has existed for 10 years and is not closing (OECD).
Women’s low pay increases poverty.
Factors contributing to women’s lower pay include maternity, parental leave, violence/sexual harassment in the workplace, the glass ceiling, the sticky floor and lack of social protection. The U.S. is one of only two countries in the world without a mandatory paid maternity leave for all women workers.
In 1964, the Official Poverty Measure (OPM) was 19.0, the year in which President Johnson announced a war on poverty. Since then, it has dropped but is now rising again:
1969 – 12.1%
1970s – OPM averaged 11.8% in the 1970s,
1980s – 13.8%
1990s – 13.8%
2000-2009 – 12.5%.
Over the entire period 1964 through 2009, the OPM averaged 13.0%.
2010 – 15.1%
2011 – 15.0%
2012 – 15.0%
Two percent of the U.S. population is over 6 million more people in poverty.
More than one in seven women, nearly 18 million, lived in poverty in 2013. About 43 percent of these women (7.8 million) lived in extreme poverty, defined as income at or below 50 percent of the federal poverty level. More than 1 in 16 women lived in extreme poverty in 2013. This is a historically high rate according to the National Women’s Law Center.
The poverty rate for women (14.5 percent) was 3.5 percentage points higher than it was for men (11.0 percent). The extreme poverty rate for women (6.3 percent) was 1.5 percentage points higher than it was for men (4.8 percent). Poverty rates were about one in four, among Black (25.3 percent), Hispanic (23.1 percent), and Native American (26.8 percent) women. Rates for foreign-born women (19.0 percent), White, non-Hispanic women (10.7 percent), and Asian women (11.0 percent) were also considerably higher than the rate for White, non-Hispanic men (8.0 percent) (National Women’s Law Center).
The poverty rate for female-headed families with children was 39.6 percent, compared to 19.7 percent for male-headed families with children and 7.6 percent for families with children headed by a married couple. Nearly six in ten of all poor children (58.8 percent) lived in families headed by women. Nearly 522,000 single women with children (12.0 percent) who worked full time year round in 2013 lived in poverty.
Among people 65 and older, more than twice as many women (nearly 2.9 million) as men (over 1.3 million) lived in poverty in 2013. The poverty rate for women 65 and older was 11.6 percent, 4.8 percentage points higher than the poverty rate for men 65 and older (6.8 percent). Nearly one in five (19.0 percent) women 65 and older living alone lived in poverty, compared to 11.3 percent for men 65 and older living alone.
When women are poor, children are poor. Nearly 14.7 million children lived in poverty in 2013, more than two out of five of whom (44.2 percent) lived in extreme poverty. One in five (19.9 percent) children were poor. The rate was one in three for Black children (38.3 percent) and Native American (34.9 percent) children and three in ten for Hispanic (30.4 percent) and foreign-born (28.4 percent) children. The poverty rate was 10.1 percent for Asian children and 10.7 percent for white, non-Hispanic children. (UNICEF, in Child Poverty, Buchheit, Alternet, April 15, 2015.)
When pay is unequal, everyone suffers, especially children. In the past six years, U.S. wealth grew 60%; during the same period, homeless children grew 60%. As UNICEF reports, "[Children's] material well-being is highest in the Netherlands and in the four Nordic countries and lowest in Latvia, Lithuania, Romania and the United States.” "Over half of public school students are poor enough to qualify for lunch subsidies, and almost half of black children under the age of six are living in poverty. http://stateofworkingamerica.org/fact-sheets/poverty/. Nearly half of all food stamp recipients are children, and they averaged about $5 a day for their meals before the 2014 farm bill cut $8.6 billion (over the next ten years) from the food stamp program. In 2007 about 12 of every 100 kids were on food stamps. Today it's 20 of every 100. For every two homeless children in 2006, there are now 30 on a typical frigid night in January. According to the U.S. Department of Housing, 138,000 children were without a place to call home. That's about the same number of households that have each increased their wealth by $10 million per year since the Great Recession.
Educational equity has not improved pay equity.
Women are 50.8% of the entire U.S. population. They represent:
60% of undergraduate degrees
60% of masters degrees
47% of law degrees
48% of medical degrees
44% of masters in business & management,
37% of MBAs
In the overall labor force they represent:
47% of the labor force
59% of the college-educated, entry-level workforce
They hold 52% of professional level jobs but only
15% of executive officers
8% of top earners
5% of Fortune 500 CEOs
In the financial industry, they are 54.2% of labor force, but:
12% of executive officers
18% of board directors
0% of CEOs
Germany mandates 30% women on boards; Norway mandates 40% as does Iceland.
In the health and social assistance fields, they are 78% of labor force yet:
15% of executive officers
12% of board directors
0% of CEOs
In the legal/medical/science fields, they are:
45% of associates of law firms
25% of non-equity partners
15% of equity partners
34% of all physicians & surgeons
16% of medical school deans
9% of management positions in info tech,
14% of senior positions at Silicon Valley startups
On all U.S. boards, women have been stuck at 12% for more than a decade. On Fortune 500 boards, they have been stuck at 17% for more than eight years. (Ms Magazine)
Women of color suffer even more.
Today women earn $.77 for every dollar earned by comparable men, which is not much improvement since 1990. But the figures are even lower for women of color:
African-American $.64 (2010)
Latina $.55 (2010)
Whites $.78 (2010)
Because of these pay inequities, women lose an average of $434,000 in lifetime.
Men lost the most jobs in the Great Recession in construction and manufacturing. However, in the recovery men gained all the jobs (93,700), while women lost 102,000 jobs. The result is that women have higher unemployment rates than men:
African American women 11%, Latina 10%, White 8%, white men approximately 5%. Women of color are also over-represented in low wage sector with few benefits.
The pay gap results in a wealth gap:
Single white men have wealth of $43,800 v. single white women of $41,500
Single Black male, $7,900 v. single Black female, $100;
Married or cohabitating white households, $167,500
Married or cohabitating African American households, $31,500
Latina household, $120
African American and Latina women with children, 0
Female minimum-wage workers have doubled since 2007 and are now twice that of males. Working poor Latina and African American women are twice that of whites. Working poor rates increased since the recession and even more since the 2009 “recovery” from 5.1% to 6% to 7% in 2011. Poverty rates for women of color are twice that of white women (The State of Women of Color in the United States: Too many barriers remain for this growing and increasingly important population, Farah Ahmad and Sarah Iverson, October, 2013, Center for American Progress).
The U.S. has a higher degree of income inequality than almost any other developed country. Only three of 34 OECD members rank higher – Chile, Mexico and Turkey.
Americans now are less likely to move to the class above their parents than citizens of other rich countries; current generations will die sooner than their parents and have less wealth.
The Special Rapporteur visited the U.S. in 2015 and in her report said, "The United States, as economic leader of the world, lags behind in providing a safety net and a decent life for those of its women who do not have access to independent wealth, high salaries or economic support from a partner or family" (UN Working Group, Dec. 2015). A 21 percent gender wage gap is "affecting women’s income throughout their lives, increasing women’s pension poverty."
The UN Working Group also said it was "shocked" by the lack of mandatory standards for workplace accommodation for pregnant women, post-natal mothers, and persons with care responsibilities, which it noted "are required in international human rights law.” International human rights law requires the establishment of social protection floors for core economic and social needs, provision for paid maternity leave, and the taking of all appropriate measures to produce ”de facto equality between all women and men in the labor market and in women-owned businesses," the statement reads.
It is clear that the pay gap continues. Gathering data is the beginning of changing policy. We must change policy if we intend to truly bring about equality. EEOC should be leading that charge. Thank you.