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VETS Explains Data Collection and Filing Periods for VETS-4212 and EEO-1

On July 24, 2017, the U.S. Department of Labor’s Veterans’ Employment and Training Service (VETS) sent a letter clarifying the data collection and reporting periods for the VETS-4212 and EEO-1 reports. The letter explains that contractors may use the same data collection period for the reports, but they must be filed during separate time periods.

Concurrent Data Collection Periods

Contractors are required to submit “workforce snapshots” on the VETS-4212 and EEO-1 reports. In 2016, the U.S. Equal Employment Opportunity Commission (EEOC) stated that the workforce snapshot period for the EEO-1 report could be any pay period between October 1 and December 31 of the reporting year. Generally, the VETS-4212 workforce snapshot period is between July 1 and August 31. This discrepancy would require contractors to pull separate workforce snapshots for the VETS-4212 and EEO-1 reports.

VETS’s July 24, 2017, letter states that its regulations “allow contractors to select December 31, as the basis for reporting the number of employees as the ending date of the twelve month period, if the federal contractor has ‘previous written approval’” to do so. Further, it explains that the EEOC’s notice on the revised EEO-1 report provides written approval to select the December 31 date for all contractors that must file VETS-4212 forms. Thus, if the new EEO-1 reporting requirement remains the same, beginning in 2018, contractors can select December 31 of the preceding year for their workforce snapshots for both the VETS-4212 form and the EEO-1 report.  

This clarification is a welcome relief for contractors, as a shared data collection period can increase efficiency and reduce administrative burdens.

Separate Reporting Periods

In previous years, contractors were required to file the EEO-1 and VETS-4212 reports by the end of September. But in 2016, the EEOC implemented a new reporting deadline for the EEO-1 report: March 31. The VETS-4212 form’s filing period remains August 1–September 30. VETS’s July 24, 2017, letter explains that contractors may not file their EEO-1 and VETS-4212 reports concurrently; the filing periods for these reports remain separate. However, it did note that “such a rulemaking could be considered in a future update.”

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About this Author

Kiosha H. Dickey, Employment Attorney, Ogletree Deakins, Law Firm
Of Counsel

Kiosha is a 2004 graduate of Columbia College, where she majored in English and minored in Political Science. She earned her Juris Doctor degree from the University of South Carolina School of Law in 2007. After law school, Kiosha clerked for the Honorable J. Michelle Childs (former Circuit Court Judge, Fifth Judicial Circuit and current U.S. District Court Judge, District of South Carolina). Kiosha joined the team at Ogletree in August 2015, where she is a member of the Affirmative Action and OFCCP Compliance Group.

Prior to joining Ogletree, Kiosha spent over...

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KyraAnne Gates is a Legal Editor of Firm Publications, working on the firm’s print and online legal publications and content. KyraAnne’s editorial responsibilities include editing the firm’s eAuthority email product, attorney-authored blog posts, firm newsletters, and a variety of other articles. In addition, KyraAnne works with outside legal publishers to produce monthly newsletters and other legal content.

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KyraAnne received her law degree from the University of Southern California, Gould School of Law. Prior to law school, she graduated with highest honors from the University of California, Santa Barbara with a B.A. in Global Studies.