FCC Announces EEO Mid-term Reviews Begin June 1 and New Online Public Inspection File EEO Mid-term Requirement for Radio Stations

The FCC announced today via Public Notice that mid-term EEO reviews for radio stations in DC, Maryland, Virginia, and West Virginia will begin on June 1. We discussed EEO mid-term reviews earlier this year in anticipation of this announcement.

• The Public Notice stated that each television station that is part of an employment unit of five or more full-time employees and each radio station that is part of an employment unit of 11 or more full-time employees is subject to" this mid-term EEO review.

This mid-term review will entail the FCC staff checking the relevant stations' Online Public Inspection Files (OPIFs") to evaluate both: (1) the annual EEO Public File Report due on June 1 and (2) the next most recent EEO Public File Report uploaded.

• The Commission also announced that when radio stations upload their EEO Public File Reports to the OPIF for mid-term reviews, they will be required to indicate whether their employment unit has 11 or more full-time employees. Stations will do so from the Settings section of the OPIF under a new Mid-term Review" tab. This will identify to the FCC which radio stations uploading EEO Public File Reports are subject to mid-term reviews.

• When television stations upload their EEO Public File Reports to their OPIFs, they will not be required to answer this question regarding the number of employees in their employment unit because their threshold for triggering mid-term reviews is the same as the threshold that requires an EEO Public File Report to be uploaded in the first instance. Accordingly, the television station OPIFs will not have a Mid-term Review" tab.

If you have any questions regarding EEO mid-term reviews, answering the new question in the OPIF, or if you need assistance with your EEO Public File Report, please contact your friendly FHH attorney.