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Quick Hits
- The 2024 VETS-4212 reporting platform will open on August 1, 2024.
- All 2024 VETS-4212 filings are due by September 30, 2024.
- Federal contractors and subcontractors with a single covered contact of $150,000 or more are required to file VETS-4212 reports.
- The same data can be used for both the 2023 EEO-1 and 2024 VETS-4212 reports provided conditions are met.
While there have been some updates to the U.S. Department of Labor’s (DOL) Veterans’ Employment and Training Service’s (VETS) frequently asked questions (FAQ) provided on the VETS-4212 landing page, there do not appear to have been any recent major changes to the VETS-4212 reporting process or form. This is in contrast to the EEO-1 filings where changes from the last few years have included different opening and closing dates, a new report form, a new filing platform, and the rollout of the requirement for government contractors to use unique entity identifiers (UEIs) instead of DUNS numbers.
Who must file VETS-4212 reports?
Federal contractors or subcontractors with a single contract of $150,000 or greater, regardless of the number of employees, are required to file VETS-4212 reports. VETS states in its FAQ guidance that the contract or subcontract may be with “any department or agency of the United States” and include procuring personal property and services such as “utility, construction, transportation, research, insurance, and fund depository.” The FAQs state that this filing requirement applies to banks, financial institutions, or private sector entities insured by the Federal Deposit Insurance Corporation (FDIC) if a single contract meets the dollar threshold. Federal contracts can include “agreements to serve as fund depositories, agreements for federal share and deposit insurance, and agreements to serve as an issuing and paying agent for U.S. savings bonds and savings notes.”
What data must be filed?
The VETS-4212 form posted for the 2023 reports is split into two data sections for the reporting location. On the left side of the form, Column A shows the total number of protected veterans broken down into the ten EEO-1 occupational categories, and Column B shows the total number of employees in each of the ten EEO-1 occupational categories. The right side of the data section shows hiring activity for the report location for the last twelve months, including the total number of protected veteran hires during the previous twelve months in Column C and the total number of hires in Column D. The form does not require that hiring activity be broken down by EEO-1 occupational category. The upper part of the form contains company identification information and information on the location for which the VETS-4212 form is being filed. While the 2024 form has not yet been posted, we anticipate it will be the same as the 2023 form.
Can data from the 2023 EEO-1 reports be used for the 2024 VETS-4212 reports?
Yes, provided that the data for the 2023 EEO-1 data was taken from the last full pay period of 2023. While a standard approach for filers who want to use the same data for both the 2023 EEO-1 and 2024 VETS-4212 form is to use data with an ending date of December 31, 2023, that is not required. Instead, the FAQs make it clear that the DOL, which administers these filings, will not cite filers for using an ending date that is not December 31, 2023, provided that the selected ending date is on the last date of the final full pay period in 2023.
Will filers receive notices of the platform opening or notices of failure to file?
No, unlike the U.S. Equal Employment Opportunity Commission (EEOC), which regularly posts updates to its EEO-1 filing page and sends numerous emails to filers, VETS does not send emails about platform openings, deadlines, filing updates, and overdue filings. This is another way that the VETS-4212 reports are distinguished from the much noisier EEO-1 reports. The VETS posts information for each filing period on the reporting landing page and leaves it to filers to complete their filings by the deadline.
Covered government contractors and subcontractors may want to consider making preparations now so they can complete their required filings by the September 30, 2024, deadline.
Ogletree Deakins’ OFCCP Compliance, Government Contracting, and Reporting Practice Group will continue to monitor developments and will provide updates on the Government Contractors and OFCCP Compliance, Government Contracting, and Reporting blogs as additional information becomes available.
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