The APA wrote to the Illinois Department of Labor (IDOL) on August 31, 2021, requesting an opportunity to collaborate with IDOL regarding provisions in S.B. 1480 (Pub. Act 101-0656), as revised by S.B. 1847 (Pub. Act 102-0036), that amend the Equal Pay Act of 2003 to add equal pay registration certificate requirements. The IDOL accepted APA’s request and met with APA staff and members on September 15.
APA’s Comments
Here are some concerns APA raised:
- The March 2022 start date may not afford sufficient time for some employers to prepare.
- The provision that IDOL can collect any other information deemed necessary raises uncertainty.
- Current federal reporting uses two categories for gender, female and male, but IDOL could request a third category, non-binary.
- Guidance is needed to clarify how to identify the applicable county for each employee under the current work environment.
- The IDOL should consider the definition of “start date” because employees may be hired, terminated, and then rehired, or shift between related employers during a reporting period.
- A clear definition for “total wages” is needed to ensure compliance because multiple definitions exist in state law.
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Alice P. Jacobsohn, Esq., is Director of Government Relations for the APA.
