Employers with federal contracts worth $100,000 or more entered into on or after December 1, 2003 will now be required to file a new form, VETS-100A, with the Veterans’ Employment and Training Service (VETS). Covered federal contractors must begin collecting the new information this summer and file their first annual reports on the VETS-100A form by September 30, 2009.
Employers working on federal contracts of $25,000 or more that predate December 1, 2003 must continue to file the VETS-100 form. Some employers with contracts falling into both categories will be required to file both forms, although VETS predicts that most contractors will file either the VETS-100 form or the VETS-100A form but not both. Modifications of pre-December 2003 federal contracts made on or after December 1, 2003 create new contracts. Contractors subject to such modified contracts need only track and report under the new VETS-100A form for the modified contract – and only if the contract meets the $100,000 threshold.
The requirement for filing the new VETS-100A form comes after VETS issued a final rule on May 19 implementing the 2002 Jobs for Veterans Act (JVA), which requires federal contractors to file annual reports on their employment of covered veterans. Signed in 2002, JVA amended the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). JVA and VEVRAA require companies with federal contracts to take affirmative action on behalf of veterans and to annually report their employment of covered veterans.
In sum, JVA raised the threshold for covered federal contracts entered into after December 1, 2003 from $25,000 to $100,000. It also revised the reporting categories to include disabled veterans, other protected veterans, armed forces service medal veterans, and veterans recently separated from military service. Notably, it eliminated Vietnam era veterans from coverage unless they fit into another category.
