Tag Archives: VETS-100

OFCCP Publishes New FAQs on the Collection of Self-Identification Information for Protected Veterans

On January 20, 2015, the Office of Federal Contract Compliance Programs (“OFCCP”) published two Frequently Asked Questions (“FAQs”) addressing what self-identification information contractors are required to solicit from protected veterans during the post-offer stage of the application process.  Specifically, in light of the new VETS-4212 Form that does not require information on the specific protected veteran categories, OFCCP considered whether, contractors must continue to solicit information about the specific protected veteran category or categories that an applicant falls into during the post-offer stage, or whether contractors can more broadly invite applicants to self-identity as protected veterans.  OFCCP decided that contractors need not collect such category-specific data during the post-offer stage:

[S]ince the new VETS-4212 report no longer requires contractors to provide this information by the individual protected veteran categories, contractors are not required to invite self-identification by category in order to comply with VEVRAA’s post-offer invitation requirement.  Rather, contractors need only invite those offered a job to indicate whether they are protected veterans under any of the VEVRAA categories.

This marks a change from the previous post-offer requirement.  The underlying self-identification requirements come from OFCCP’s current regulations, issued on March 24, 2014, which require contractors to invite applicants to voluntarily self-identify their protected veteran status during both the pre-offer and post-offer stages of the application process.  For the pre-offer stage, contractors are not required to invite applicants to self-identify their specific protected veteran categories.  There is no change to this requirement. At the post offer stage, which includes the period after candidates receive offers of employment but before they began working, contractors were required to invite applicants to self-identify the specific category or categories of protected veteran to which they belong, which includes recently separated veterans, disabled veterans, Armed Forces service medal veterans, and active duty wartime or campaign badge veterans.

Until now, the reason for the category-specific data at the post-offer stage was needed to complete the Veterans Employment and Training Services (“VETS”) VETS-100A Form. However, in September 2014, after OFCCP’s veteran regulations had gone into effect, VETS released a new VETS-4212 Form to replace the VETS-100A form.  Under the new VETS-4212 form, contractors are only required to report aggregate data on the number of protected veterans rather than the specific categories of protected veterans.  On this basis, OFCCP reasoned in the new FAQs that contractors are no longer required to solicit information about the specific categories of protected veterans.

OFCCP, however, stated that contractors may still solicit such information.  In deciding whether to continue soliciting the specific protected veteran categories from applicants at the post-offer stage, contractors should weigh the value of this more detailed information with the burden of the additional recordkeeping and the risk of collecting information that is no longer required by OFCCP.

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Filed under Department of Labor, OFCCP, Office of Federal Contract Compliance Programs, Veterans

VETS Extends Deadline for VETS-100 Report Due to Hurricane Sandy

The Veterans Employment and Training Services (“VETS”) announced that the deadline for filing electronic or paper VETS-100 and 100A reports has been extended until November 9, 2012 in light of the damage caused by Hurricane Sandy.  According to VETS, “all paper reports and electronic files received by November 9th will be included as part of the 2012 filing cycle and will not be considered late.”

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VETS-100 Reports Deadline Extended to October 31, 2012

The Veterans Employment & Training Services (“VETS”) announced that the deadline for filing electronic or paper VETS-100 and 100A reports has been extended from September 30, 2012 to October 31, 2012.  As we reported last year, VETS had to extend the deadline twice because it was experiencing technical issues with its new electronic filing system.  Although VETS has not publicly reported any issues with its online filing system, many in the contracting community have reported that the recent extension is due to continuing technical difficulties with that system.

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DOL VETS-100 Online Filing System Now Operational

On November 1, 2011, the DOL announced that contractors can now submit their VETS-100/100A reports electronically using the VETS100 reporting application.  DOL indicated that all contractors must register for the 2011 cycle whether or not they have previously registered.  Contractors can register at vets100.dol.gov and will have until December 30, 2011 to file their VETS-100/100A reports.

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DOL Provides Further Extension of VETS-100 Reports Deadline

The DOL announced earlier this week that it was extending the deadline for contractors to submit their VETS -100 and VETS-100A reports until December 30, 2011. We reported a couple of weeks ago that DOL had extended the deadline for filing VETS-100 and VETS-100A reports until November 30, 2011 because of technical problems it was experiencing with its electronic filing system.  The DOL had indicated that it would have the electronic filing system ready on or before October 1, 2011. Continue reading

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VETS-100 Report Delay

The Department of Labor (“DOL”) has announced that it will allow contractors to file VETS-100 and VETS-100A reports until November 30, 2011 because of technical problems it is experiencing with its electronic filing system.  The DOL had planned to begin accepting electronic submissions of the VETS-100 reports on August 1, 2011, but, because of various technical issues, DOL will not have the electronic filing system ready until October 1, 2011. Continue reading

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Filed under Department of Labor, OFCCP, Veterans