
In keeping with the updated VEVRAA
regulations that became effective earlier this year, the new VETS rule replaces
the term "covered veteran" with "protected veteran," which
is defined to include the four categories of: (1) "disabled veteran";
(2) "recently separated veteran;" (3) "activity duty wartime or
campaign badge veteran;" or (4) "Armed Forces service medal
veteran." The bigger change,
though, is that while the old VETS-100A Report required contractors to specify
the categories of covered veterans they hired or employed, the new VETS-4212
Report only requires that contractors report protected veterans in the
aggregate, without specifying whether an individual belongs to one or more of
the four categories of protected veterans.
The change to reporting protected veterans in the aggregate
has three main benefits. First, it
provides added privacy to disabled veterans. Previously, contractors had to specify on their publicly available
report that a disabled veteran worked in a certain job group. Now that the new report only requires the
employer to report a "protected veteran" in that job group, it is
more difficult to figure out who might be a disabled veteran just by looking at
the report. Second, this change will
eliminate double counting of a single veteran who may meet the definition of
two or more of the four categories. Finally,
the VETS is predicting that the new approach will save federal contractors
money, and who doesn’t like that?
The new rule also completely eliminates the VETS-100 report,
which applied to contracts entered into prior to Dec. 1, 2003, because these
contracts no longer exist. In addition, the rule sets forth electronic
filing requirements and amends mandatory contract clauses relating to the
report. While the rule officially
becomes effective Oct. 27, 2014, the practical effective date of the new
rule will be the 2015 reporting period, which runs from Aug. 1st to Sept.
30th. In the meantime, contractors
should be sure their self-identification forms include the new definitions and
are otherwise up-to-date with the VEVRAA regulations that became effective
earlier in the year.
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