Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.
On August 1, 2018, the DOL’s Veterans’ Employment and Training Service (VETS) opened the filing season for the 2018 VETS-4212 report. The VETS-4212 report is an annual report that provides information regarding the number of protected veteran employees in each job category, as well as the number of protected veteran new hires for the preceding 12-month period by job category. Covered federal contractors and subcontractors must file the 2018 VETS-4212 report if they held a federal contract or subcontract valued at $150,000 or more at any point during calendar year 2017. The deadline for filing the report is September 30, 2018.
Covered contractors have two options for data snapshots in 2018. One option is for contractors to use an employee file from a payroll period between July 1, 2018 and August 31, 2018. A second option is for contractors with “written approval from EEOC to use December 31 as the ending date for the EEO-1 Report” to use that date as the ending date for the payroll period selected for the VETS-4212 report. Importantly, EEOC gave this written approval to all contractors required to file a VETS-4212 report on July 14, 2016. Therefore, companies that completed their 2017 EEO-1 reports using a December 31, 2017 snapshot may use that same snapshot to file their 2018 VETS-4212 report.
Contractors that can use their December 31, 2017 snapshot should consider the pros and cons of such an approach. On one hand, using the same snapshot for both the EEO-1 and VETS-4212 reports is easier from an administrative burden perspective. On the other hand, the contractor is not providing the most up-to-date protected veteran employee counts or hiring data in its 2018 VETS-4212 report.
In terms of the actual filing, there are no changes to the VETS-4212 filing rules for 2018 and contractors can use any of the following methods to meet their reporting requirement: online completion, electronic submission, or paper submission. Lastly, upon successful submission of the report, contractors will receive an email confirmation of receipt notification for their records.
