If they have an EIN they are claiming to be "an agency or instrumentality of the US government" - or possibly the State government. That's the definition of an "employer". And when it comes to sexual harassment the EEOC would apply. It should apply to this example as well.
If they have an EIN they are claiming to be "an agency or instrumentality of the US government" - or possibly the State government. That's the definition of an "employer". And when it comes to sexual harassment the EEOC would apply. It should apply to this example as well.