The Department of Labor Changes Contractors’ Reporting Obligations Concerning Protected Veterans
On September 25, 2014, the Department of Labor Veterans' Employment and Training Services Agency (VETS) published the final rule amending the regulations that require federal contractors to annually report the total number of employees and new hires belonging to categories of veterans protected under the Vietnam Era Veterans' Readjustment Assistance Act of 1974, as amended (VEVRAA). The final rule rescinds in full 41 CFR Part 61-250 which applies to contracts of $25,000 or more entered into prior to December 1, 2003, unless amended on or after that date to a value of $100,000 or more. The final rule amends 41 CFR Part 61-300 which applies to government contractors or subcontractors who enter into a government contract or subcontract of $100,000 or more for "the procurement of personal property and non-personal services (including construction) . . ." 41 CFR 61-300.1
Beginning with the 2015 reporting period, instead of filing an annual VETS-100 or VETS-100A, federal contractors and subcontractors will be required to file a VETS-4212 Report. Contractors must file the VETS-4212 between August 1 and September 30 of each year following a calendar year in which that contractor held a contract or subcontract. Contractors with 10 or more business or hiring locations must file the VETS-4212 electronically using the VETS electronic filing system or by submitting the Report in an alternate electronic format, such as a flash drive. Contractors with less than 10 business or hiring locations may file a paper version of the VETS-4212. Further, contractors are no longer required to report on the number of protected veterans by specific veteran category. The VETS-4212 permits contractors to report the number of protected veterans in the aggregate.
For more information please contact your Butzel Long attorney or the author of this client alert.
Regan K. Dahle