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Are prime contractors obligated to inform its subcontractors (via subcontract mods for example) to file their EEO-1 reports?  Should we expect Agencies to modify prime contracts to address EEO-1 reporting requirements?

 

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I'm guessing here that there are EEO clauses in the prime contract (e.g., 52.222-26) and that those clauses not only refer to the filing requirements, they also require the prime contractor to take AFFIRMITIVE actions to assure equal opportunity and to flow down the requirements to applicable subcontracts. 

I say that I am guessing, because your initial post was too obscure to understand your perceived concern or perceived lack of responsibility for EEO compliance by subs that are subject to the EEO reporting requirements.  Note that subcontract labor size thresholds are are lower than those where the sub is a prime.  

EDIT: In reviewing your previous posts in the WIFCON forum, it appears that you are a sub. From the scant OP description, I don't see any need for the government to modify its contract with the prime.  As for the actual filing requirements for certain subcontractors on federal contracts, it's required by Federal Law, as referenced in my first response.

 

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Thanks for the response.  No, we are the prime and folks in our HR dept. and maybe "compliance" are indicating that we would have to issue sub mods to make them (the subs) aware of this EEO-1 reporting responsibility;However, I don't feel that Contracts has to be involved in this. The subs should be aware of the EEO responsibilities.

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Yes, great. And if your company has included the requisite EEO clauses in your subcontracts, then the sub(s) are also directly on notice of their filing responsibilties under the law. 

It doesn't hurt to remind them but no mod is necessary. 

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If FAR 52.222-22 was included in your prime, per(c) you should have obtained a certification before awarding the subcontract.

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