10 Actions Employers Can Take To Secure Equal Pay for Black Women

By Jocelyn Frye, Senior Fellow

Center for American Progress

Black women had to work seven-and-a-half months past 2019—until August 13—to earn what their white male counterparts earned in 2019.

August 13, 2020 — Black Women’s Equal Pay Day marks the day in the current year when Black women finally catch up to the earnings that white men received over the course of the prior year. In 2020, Black women had to work seven-and-a-half months beyond 2019—until August 13—to earn what their white male counterparts earned in 2019.

The disparity between Black female and white male earnings, unfortunately, is not new. In 2018, Black women working full time, year round earned an estimated 62 cents for every dollar earned by white male full-time, year-round workers. This nearly 40 percent gap in earnings reflects the combined impact of long-standing racial and gender pay disparities. While a portion of these disparities can be explained by measurable factors such as differences in seniority or education, a significant portion—estimated to be as high as 38 percent of the overall gap—cannot be explained by such factors. It is this portion that researchers often attribute to discrimination.

There is a critical need for action at all levels to address the pay discrimination that Black women experience, from congressional action on pending proposals such as the Paycheck Fairness Act to robust executive actions by the administration, such as increasing the number of compliance reviews to assess federal contractor pay practices; state innovations to limit the misuse of salary history; and actions within individual workplaces.

Such action is especially important given Trump administration efforts to roll back important progress on equal pay by moving to discontinue the collection of employers’ compensation data. Employers have a particularly pivotal role to play in setting the tone and establishing pay practices within workplaces, and they must be front and center in this work to correct the disparities that have eroded Black women’s pay for decades.

Here are 10 concrete actions that employers can take to address Black women’s pay gap.

1. Undertake a compensation audit

Employers should undertake a compensation audit that looks at racial, ethnic, and gender pay differences on an annual basis. Such an internal audit enables a company to examine pay differences confidentially across an organization and take concrete steps to close the gaps that are uncovered. To the extent that employers find unexplained pay gaps for Black women, corrective measures taken expeditiously can help undo these disparities and raise their wages.

2. Provide greater pay transparency

Pay disparities are often difficult to detect. Greater pay transparency could help provide Black women with better information about where pay gaps exist, which job opportunities could be the most equitable and promising, and where corrective action may be needed. It is especially important for employers to provide more transparency about pay differences broken down by factors such as race, gender, and ethnicity to promote better understanding of workers’ diverse experiences. Researchers have found that pay data disclosure by employers can help close pay gaps within the workplace.

There are many different models that employers can draw from in deciding how best to disclose compensation information.

In the United Kingdom, for example, companies with 250 or more employees—including many U.S.-based employers with offices in the United Kingdom—are required to report their gender pay gap.

Employers modeling this type of reporting could publish or make available to employees disaggregated data to show the overall racial and gender pay gaps within a company and provide more visibility into pay differences not only for Black women but for all workers across race and ethnicity. 

Another option for employers is to post salary ranges for open positions so that all applicants have a better understanding of the expected wages associated with a position. Still another option is for employers to publish their pay data utilizing the occupational categories in their EEO-1 form submission, a standard form that employers with 100 or more employees are required to file yearly with the Equal Employment Opportunity Commission. Using this approach, an employer could publish pay data broken down by race, ethnicity, and gender across the form’s broad occupational categories to help pinpoint potential problems. Any or all of these options could help shed light on where pay disparities experienced by Black women are occurring.

3. Undertake job analyses to identify comparable jobs and disrupt occupational segregation

It is important to ensure that the jobs that Black women hold are compensated equitably in comparison to other jobs within a workplace. This is particularly necessary because many Black women are frequently clustered in jobs that are lower-paying and that offer fewer promotional opportunities. Employers should assess the different jobs within their workplaces to identify jobs that are comparable—for example, jobs that require similar types of skills or functional activities.

Just because two jobs have different titles does not mean that they are not “equal” or substantially the same for purposes of establishing the appropriate pay level. 

Commissioning an objective analysis of the different positions within a company and the different components of each job could help identify which jobs are comparable. 

Similarly, employers can undertake an analysis of their workforces to determine whether Black women—or other workers—are siloed in certain types of jobs. If such occupational segregation exists, employers can take steps to make adjustments where necessary to raise wages and promote comparable pay levels across job categories, achieve greater diversity within occupations, and increase the numbers of Black women in higher-wage jobs. These types of analyses could help show where pay adjustments are needed and could create new opportunities for Black women.

4. Raise the minimum wage and eliminate tipped and subminimum wages

Black women disproportionately work in low-wage jobs, particularly jobs that pay at or near the minimum wage. They also are overrepresented in what are known as tipped occupations—jobs where workers are paid less than the federal minimum wage because there is an expectation that these workers will earn the equivalent of the minimum wage when tips are added to their pay. This type of subminimum wage also affects certain workers with disabilities, whose employers are permitted to pay them a wage lower than the federal minimum wage for the work that they perform. 

Raising the minimum wage and eliminating the tipped minimum wage and subminimum wage for workers with disabilities would help increase the wages of many Black women and help them make ends meet. Employers can take comparable action on their own to increase the wages of employees working in minimum wage jobs to ensure that they are earning at least $15 per hour. Employers also can take steps to remove barriers to collective action and union organizing, which can help create spaces for workers to discuss their wages and engage with employers.

5. Discontinue use of salary history in hiring and compensation decisions

Employers should make a commitment to prohibit the use of salary history when making hiring or compensation decisions. Using salary history to determine whether to hire a person, or whether to set an individual’s new salary based on their previous salary, means that Black women—indeed, all women—are perpetually connected to salaries that may be infected with discrimination. Establishing a clear prohibition against this would help ensure that the pay level for a particular job is based on factors related to the job being performed instead of other, extraneous factors.

6. Commit to an equal pay ‘right to request’ or ‘bill of rights’

Employees too often are in the dark about how pay decisions are made within their workplace and about their employer’s overall pay policies. Establishing an equal pay “right to request” or “bill of rights” would help ensure that all employees have access to basic information about pay practices and policies within an organization. Such information could include the employer’s equal pay policy, the salary range for open positions, a description of the process used to determine pay raises, information on gender and racial pay gaps within the company, and information on how frequently compensation audits are undertaken. Having this type of information available would establish a baseline level of understanding for all employees, including Black women, and allow for greater clarity about an employer’s pay policies.

7. Establish an internal working group with senior-, mid- and junior-level representation to foster greater understanding about pay practices

Creating a working group or task force with representation from across an organization can foster better communication about employer pay practices and provide an additional layer of transparency about the process for determining wages. Such a working group would not make pay decisions or be involved in setting pay levels; rather, it would provide a forum where questions and problems could be surfaced and discussed. This group could elevate specific concerns about pay disparities facing Black women or other groups of workers and delve into specific strategies that could be deployed across the organization to ensure that pay policies are evenly administered.

8. Elevate more Black women into leadership positions

Establishing a strong commitment to equity, as reflected in the policies and practices utilized throughout an individual workplace, can help foster a climate and culture where pay discrimination is not permitted to take root. Research studies have found that greater numbers of women in leadership can help reduce different forms of workplace discrimination such as sexual harassment and expand opportunities for women.

Increasing the number of Black women at the highest levels of an organization not only helps break previously impenetrable glass ceilings but also can broaden perceptions of where Black women fit within a company and help ensure that Black women are seen as valued workers.

Employers should undertake targeted efforts to include Black women at every level—on boards, in executive leadership, and in managerial roles across different types of functional and programmatic teams throughout the company.

9. Adopt robust policies to address work-family conflicts and financial insecurity

Improving Black women’s wages is only one part of a comprehensive strategy to ensure that Black women are treated fairly in the workplace and achieve more economic stability. Many Black women work in jobs that lack critical workplace supports such as paid sick leave and access to back-up care in emergency situations. The absence of these types of supports can make it harder for Black women, and other women workers, to navigate their work and family responsibilities and can create untenable choices between putting their job or their family at risk.

Further, many Black women lack the overall wealth—which goes beyond earnings to encompass savings, retirement, and other financial assets—to sustain themselves through different economic emergencies or the inevitable financial ebbs and flows that occur over time.

Employers can address these concerns by adopting strong work-family policies such as paid family and medical leave and ensuring that workers have equal access to other types of critical benefits within organizations, including retirement benefits, comprehensive health coverage, and work bonuses.

10. Provide comprehensive anti-bias training for all employees

Pay discrimination often is rooted in different forms of bias, including biases about Black women and their value. These biases can lead to Black women being underpaid; being passed over for promotions; and being excluded from better, more lucrative jobs. Although diversity training is not a panacea, done well it can be an important component of a comprehensive strategy to rid the workplace of implicit and explicit biases that shape workers’ experiences. Ongoing anti-bias training is critical to combat workplace biases that devalue the contributions of Black women. Employers requiring all staff throughout the company to undertake such training on an annual basis could help counter discriminatory attitudes and create more equitable workplace environments for all workers.

Conclusion

Black women deserve to be paid fairly for their work, and the time for action is long overdue. Statements of support on Black Women’s Equal Pay Day, while important to show solidarity and commitment, are not a substitute for concrete action. Employers should take intentional steps, such as the actions discussed in this column, to address pay disparities experienced by Black women and help ensure that pay practices utilized throughout workplaces are administered in a fair and even-handed manner. This work should be a top priority for all employers and is essential to making the promise of equal pay a reality for Black women.

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Jocelyn Frye is a senior fellow at American Progress, where her work focuses on a wide range of women’s issues, including work-family balance, pay equity, and women’s leadership. Prior to joining American Progress, Frye served for four years as deputy assistant to President Barak Obama and director of policy and special projects for First Lady Michelle Obama, where she oversaw the broad issue portfolio of the first lady, with a particular focus on women, families, and engagement with the greater Washington, D.C., community.

Frye received her undergraduate degree from the University of Michigan and her law degree from Harvard Law School. She is a proud native of Washington, D.C.