On April 24, 2023 the FCC released its most recent list of broadcast stations that will be audited regarding their compliance with the FCC’s Equal Employment Opportunity (“EEO”) rules. Licensees of the audited stations will have to upload their audit responses to their online public inspection files by June 8, 2023.
Approximately twice per year, the FCC randomly selects stations for audit to ensure that they are fulfilling their EEO obligations. Broadcast “Employment Units” (as that term is defined by the FCC) with five or more full-time employees are required to recruit broadly for minority and female applicants for job openings. Recruiting broadly entails wide distribution of job postings, recruiting from community sources, and hosting events to educate the public on careers in broadcasting. For broadcast employment units with fewer than five full time employees, an audit response is still required, but response requirements are less rigorous.
Stations must also keep detailed and careful records of these recruitment activities, which they will be expected to produce when audited.
If your station is on the FCC’s EEO audit list, be sure to carefully review the instructions provided in your audit letter and if you have any questions, contact your FHH attorney for guidance.