On May 11, 2023, the FCC released a Public Notice announcing that the next EEO mid-term review cycle will commence on June 1, 2023. From June 1, 2023 through April 1, 2027, qualifying stations in all states will undergo an EEO mid-term review by Enforcement Bureau staff on the fourth anniversary of the deadline for the most recent license renewal application belonging to each station in the employment unit. Only television stations that are part of an employment unit of five or more full-time employees and radio stations that are part of an employment unit of 11 or more full-time employees are subject to the EEO mid-term review.
The EEO mid-term review will cover the two-year period preceding the mid-term review deadline. Staff will evaluate performance as reflected in a station’s annual EEO Public File Reports, and may request additional information from licensees if they deem it necessary. Staff will inform licensees of any necessary improvements in recruitment practices to ensure they are in compliance with the EEO rules and take any other appropriate action.
Radio Station Staff Employment Unit Size: As noted above, only radio stations that are a part of an employment unit with 11 or more full-time employees are subject to a mid-term review. In order to determine whether a station is subject to mid-term review, radio station licensees are required to indicate in their Online Public Inspection File whether they employ 11 or more full-time employees. This must be indicated as follows: in the Settings section of the OPIF, a new “Mid-Term Review” tab will appear; that tab will present radio stations with a “yes/no” question which licensees must answer to disclose whether their employment unit has 11 or more full-time employees. The answer will be stored in a new folder entitled “Mid-Term Review” within the EEO Public File Reports subfolder on the OPIF. Stations that answer yes are subject to review. Stations that have uploaded an EEO Public File Report at mid-term but fail to answer the question will be contacted by Enforcement Bureau staff.
Television Station Staff Employment Unit Size: All television station employment units uploading an EEO Public File Report to the OPIF are necessarily subject to a mid-term review as the requisite staff size for both obligations is five or more full-time employees. Television stations that post an EEO Public File Report to their OPIF will be automatically subject to a mid-term review. The OPIF will not present a “yes/no” question to television stations and no new sub folder will appear.
On June 1, 2023, the Enforcement Bureau will begin its review with radio station in Washington, DC, Maryland, Virginia, and West Virginia, and will proceed in order based on the date of a station’s four year renewal anniversary thereafter.
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