Holomua Consulting Group would like to say thank you to all Veterans and Active Duty Service Members for your service to our Country. Since it is Veterans Day, we thought it appropriate to report on a topic related to Veterans. On September 25, 2014, the Veterans' Employment and Training Service (VETS) of the U.S. Department of Labor issued its Final Rule revising the reporting requirements for federal contractors and subcontractors under the Vietnam Era Veterans' Readjustment Act of 1974 (VEVRAA). Practically speaking, the actual reporting aspect of the Final Rule, which became effective on October 27, 2014, does not have an impact on contractors until the 2015 Reporting Period (August 1 - September 30, 2015) Nonetheless, it is helpful for federal contractors to be aware of the changes effected by the Final Rule, as it may have an impact on contractors' current data collection practices.
As a reminder, this Final Rule and the veterans reporting requirements apply to federal contractors or subcontractors with contracts of $100,000 or more. The following is a summary of the highlights of the Final Rule:
The most significant of the changes is the ability for contractors to collect and report data on veterans in the aggregate. Under the VETS-100A reporting, contractors were required to report veteran hiring and employment data by EEO-1 category and the specific veteran category. Given the way the veterans categories are defined, an individual could fall into one ore more category, thus making it extremely difficult, if not impossible, to accurately track hiring and employment of Protected Veterans.
According to the U.S. DOL, the Final Rule is intended to reduce the reporting requirements and paperwork burden for federal contractors and subcontractors. In addition, the data collected by the VETS-4212 will "help the Labor Department develop more informative yearly trends in the employment of protected veterans."
Contractors are not required to revise their Self-Identification forms but may want to consider simplifying their Post-Offer Self-Identification form. In either case, Contractors should keep in mind that there are still additional tracking requirements and other obligations that apply to specific categories. For example, if an individual self-identifies as disabled veteran in a Post-Offer Self-Identification form, the employer has an obligation to inquire whether the individual is in need of a reasonable accommodation and if so, engage in the interactive process with the individual. If you would like more information regarding the VETS-4212, VEVRAA, and/or Veterans hiring in general, please contact us at (808) 369-9710 or through our Contact Form.
- The VETS-100A Report is now referred to as VETS-4212
- The term "Covered Veteran" is replaced with the term "Protected Veteran" (which encompasses disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, and Armed Forces service medal veterans)
- The definition of "Protected Veteran" reflects the revised VEVRAA regulations (see above)
- Contractors will now be required to report on Protected Veteran hiring and employment numbers in the aggregate rather than according to specific veteran category (as was previously required by VETS-100A)
- Contractors will have the option of reporting new hire data (protected veterans and total new hires) by EEO-1 category in a hiring location or by reporting aggregate numbers for new hires by hiring location
- Contractors with 10 or fewer hiring locations have the option of filing the VETS-4212 in paper format either electronically or via U.S. Mail
The most significant of the changes is the ability for contractors to collect and report data on veterans in the aggregate. Under the VETS-100A reporting, contractors were required to report veteran hiring and employment data by EEO-1 category and the specific veteran category. Given the way the veterans categories are defined, an individual could fall into one ore more category, thus making it extremely difficult, if not impossible, to accurately track hiring and employment of Protected Veterans.
According to the U.S. DOL, the Final Rule is intended to reduce the reporting requirements and paperwork burden for federal contractors and subcontractors. In addition, the data collected by the VETS-4212 will "help the Labor Department develop more informative yearly trends in the employment of protected veterans."
Contractors are not required to revise their Self-Identification forms but may want to consider simplifying their Post-Offer Self-Identification form. In either case, Contractors should keep in mind that there are still additional tracking requirements and other obligations that apply to specific categories. For example, if an individual self-identifies as disabled veteran in a Post-Offer Self-Identification form, the employer has an obligation to inquire whether the individual is in need of a reasonable accommodation and if so, engage in the interactive process with the individual. If you would like more information regarding the VETS-4212, VEVRAA, and/or Veterans hiring in general, please contact us at (808) 369-9710 or through our Contact Form.
