Pearl Meyer's "CEO Pay Ratio Disclosure Round Two: Top 10 Things to Worry About" identifies a laundry list of considerations for companies beginning to think about their Year 2 CEO Pay Ratio development and disclosure.
The overarching guidance is that any deviations from last year's median employee, methodology (e.g., use of statistical sampling, exclusion of foreign workers), or disclosure flow and format, should be well-considered and based on a compelling rationale so as to not unnecessarily trigger unwarranted scrutiny from investors, regulators, the media or other constituencies. That said, the firm notes several facts & circumstances-specific situations that may warrant changes in approach, and reminds us that decisions made in/for Year 2 will bear on methodology and approach for Year 3 and following.