As employers are working to file their 2014 Vets-100A Reports, the Veterans’ Employment and Training Service (VETS) is already looking ahead to the future and finalizing the form and filing requirements for 2015.

Finalizing rules proposed earlier this year, in 2015, the VETS-100A Report will be re-named the VETS-4212 Report (named after the U.S. Code section for the Vietnam Era Veterans Readjustment Assistance Act (VEVRAA) 38 U.S. Code Section 4212). Additionally, employers will no longer have the ability to file a VETS-100 Report.  This is consistent with OFCCP’s deletion of Section 250 (addressing contracts pre-dating December 1, 2003) from the VEVRAA Regulations.

Additionally, and more importantly, going forward federal contractors will no longer need to report on the different categories of protected veterans.  Instead, employers will be required to provide only aggregate numbers of protected veterans by EEO Category.

VETS says this decision provides at least two advantages.  Under current regulations it was not possible to get an accurate picture of total veterans covered by VEVRAA because a veteran might fall into more than one category and the VETS-100A Report didn’t require a total veteran workforce or hiring number.  Moreover, this change fosters confidentiality as it will be harder to discern the identity of a “disabled veteran” in a small EEO Category.

These new rules will apply to your VETS-4212 Report next year.  For 2014, your VETS-100A remains the same and must be filed by September 30, 2014 unless an extension is obtained.

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Photo of Laura A. Mitchell Laura A. Mitchell

Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She is a member of the firm’s Affirmative Action and OFCCP Defense practice group as well as the firm’s Pay Equity Resource Group. She is also on the…

Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She is a member of the firm’s Affirmative Action and OFCCP Defense practice group as well as the firm’s Pay Equity Resource Group. She is also on the leadership team for the firm’s Government Contractor Industry Group.

Her practice is focused on representing government and non-government contractors in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. Ms. Mitchell personally oversees the development of hundreds of AAPs each year and is intimately involved in the defense of numerous OFCCP audits. She also spends significant time counseling companies in connection with conducting pay equity analyses as well as government contractor employment obligations.

Ms. Mitchell is the editor and a principal contributor of The Affirmative Action Law Advisor blog and frequently presents on pay equity, affirmative action compliance, OFCCP enforcement trends, and government contractor obligations.

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