EEO Mid-Term Reviews for TV Stations Start Soon

The FCC’s rule requiring a mid-term review of EEO compliance for broadcast stations kicked in last June 1 for radio stations and will begin this June 1 for television stations.  Since license renewals are staggered by state over a three-year period, with radio starting first, and TV a year later, the mid-term review occurs using the same staggered schedule.

Licenses are issued for eight-year terms, and the mid-term review occurs four years after the deadline stations last had to file their license renewal application.  On June 1, 2024 the first television stations (those in Washington DC, Maryland, Virginia and West Virginia), will begin the cycle of TV stations having a mid-term EEO compliance review.

Unlike radio stations, where a mid-term EEO review is triggered for stations or station employment units with 11 or more full-time employees, the trigger for TV stations is only 5 or more full-time employees.  Radio stations have to tell the FCC in their online public files if they have 11 or more full-time employees, but that is not necessary for TV stations since the FCC can tell if a TV station has five or more full-time employees by noting whether the station uploads an annual EEO public file report which has the same employee threshold.

Stations do not have to submit anything to the FCC for the EEO mid-term review to take place.  The staff begins their reviews automatically, and only contacts the station if it needs more information to evaluate compliance. If a review occurs, and nothing is amiss, the station will not receive or hear anything from the FCC.