Media Bureau Launches Second Random EEO Audit of 2024

The FCC Enforcement Bureau issued an October 18^th public notice announcing its second round of random broadcast station EEO audits.  Approximately 150 broadcast radio and television stations are on the list, though some may be exempt as a result of being included in prior random EEO audits in the past two years.  If your station is on the list, step one is to upload the audit letter to the station public file in the EEO section under the EEO Audits tab.

Responses to the audit are to be uploaded to the station online public file no later than December 2, 2024, although stations can request an extension if needed.  An email to eb-eeo@fcc.gov is required along with a good cause showing.  The Bureau is pretty prompt in responding to those requests, but until they do respond and grant more time, the prior deadline remains in effect.

Due to potential impacts from hurricanes Helene and Milton, stations in Florida, Georgia, North Carolina, South Carolina, Tennessee and Virginia who need more time to respond can simply use January 16, 2025 to respond in lieu of having to request additional time.  If a station in those states has unique circumstances that makes even the January 16 deadline impossible, they should contact the Enforcement Bureau to discuss options.

As we’ve written before, full responses to a random EEO audit can take considerable time, so stations should start early. If errors to annual EEO public file reports are noted during preparation for a response, stations should not delete and upload a new report to the station public file, since that will result in the report appearing to have been uploaded late.  Instead, upload an “amendment” document to make the correction.  Good record keeping is the key to reducing the burden of responding to EEO audits.

Last month, we mentioned the scrutiny of the FCC staff during a mid-term EEO review, which applies to radio station employment units with 11 or more full-timers, or television station employment units with 5 or more full-timers.  The same scrutiny applies to random EEO audits. Stations receiving correspondence from the Enforcement Bureau requesting additional information or clarifications should respond promptly.