DOL Greenlights Aligning Data Collection Period for EEO-1 and VETS-4212 Forms as VETS-4212 Deadline Nears

The reporting cycle for the 2017 VETS-4212 report began on August 1.  While covered federal contractors have until September 30, 2017 to file the VETS-4212 report, the deadline for filing EEO-1 reports has changed to March 31, 2018.  This change coincided with the addition of summary compensation data to the EEO-1 report that employers with 100 or more employees must file.
 
Aside from the inclusion of summary compensation data, the EEO-1 report revision also changed the report’s snapshot period to the twelve-month period preceding December 31.  The shift in reporting and data collection periods for the EEO-1 has raised questions among employers who are also required to file the VETS-4212 report every year.
 
As a general matter, the VETS-4212 report must be filed by employers with federal contracts valued at $150,000.  It requires covered employers to report on affirmative action efforts in employing veterans by job category and hiring location.  Covered employers are concerned that maintaining a September 30 report deadline for this report while the the EEO-1 reporting and data collection periods have shifted, may reduce efficiency and increase the burden completing these reports.
 
These concerns were raised to the Department of Labor in a letter by the Institute for Workplace Equality earlier this year.  In its response, the agency noted that while the VETS-4212 reporting deadline would remain September 30 absent notice and comment rulemaking, employers have flexibility to align their VETS-4212 data collection period to that for the EEO-1 form.  This means that employers can use a snapshot period of the twelve-month period preceding December 31 in collecting data for the VETS-4212 form.
 
How to File
 
The U.S. Department of Labor (DOL) encourages VETS-4212 reports to be filed electronically on the VETS-4212 website at https://vets4212.dol.gov/vets4212.  Alternatively, reports may also be submitted by email (VETS4212-customersupport@dol.gov) or regular mail at:
 
VETS-4212 Service Center
C/O Department of Labor National Contact Center (DOL-NCC)
15000 Conference Center Drive, Suite B0132
Chantilly, VA 20151
 
Blank form reports for 2017 are available on the DOL Veterans’ Employment & Training Service website.