Covered federal contractors and subcontractors must annually report the number of their employees who are protected veterans, and the number of veterans they have hired during a reporting period. At long last, the U.S. Department of Labor (DOL) has issued a Final Rule changing the manner by which federal contractors report their employment of protected veterans. In addition, the DOL has submitted a revised “Federal Contractor Veterans’ Employment Report” to the Office of Management and Budget for review and approval.

The new VETS-4212 report will replace both the current VETS-100A and VETS-100 reports, beginning with the annual report filed in 2015. A federal contractor or subcontractor that enters into a procurement contract of $100,000 or more with a federal agency or department will be required to file this report, which must include the following information:

  • the total number of employees in the workforce of the contractor by job category and hiring location and the total number of such employees by job category and hiring location who are protected veterans;
  • the total number of new employees hired by the contractor during the period covered by the report and, of such employees, the number who are protected veterans; and
  • the maximum number and minimum number of employees at each hiring location during the reporting period.

“Protected veteran” is a term defined in 41 C.F.R. section 61-300.2 and includes veterans classified as disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans, or Armed Forces service medal veterans. Contractors can choose to use a reporting period between July 1 and August 31 of each year or can seek written approval to use a reporting period of December 31. The Office of Federal Contract Compliance Programs (OFCCP) will enforce the VETS-4212 filing requirements.


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OFCCP Compliance, Government Contracting, and Reporting

The experienced attorneys in our OFCCP Compliance, Government Contracting, and Reporting Practice Group advise and defend federal contractors and subcontractors on jurisdictional, compliance, and enforcement issues relevant to government contracting, including those involving the Office of Federal Contract Compliance Programs (OFCCP).

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