Federal Contractor and Subcontractor Labor Reporting Under the Vietnam Era Veterans Readjustment Assistance Act

An important annual Federal labor reporting requirement is coming due for Federal contractors and subcontractors. The Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) requires Federal contractors and subcontractors with contracts valued at > $150,000 to annually report employment data for protected Veterans in their employ.

If Federal Acquisition Regulation (FAR) Clause 52.222-37, Employment Reports on Veterans (Jun 2020)(or earlier versions of this clause) is contained in your Federal contract or has been “flowed down” to your subcontract from the prime contractor, you likely have a reporting obligation.

What is a VETS-4212 Report?

The report, known as “VETS-4212” (formerly known as VETS-100 or VETS-100A, and often referred to as such in contracts awarded using earlier versions of FAR Clause 52.222-37) is due for submission to the Veterans Employment Training Service (VETS) at the U.S. Department of Labor, no later than September 30, 2020. The fiscal Year 2020 reporting cycle began August 1, 2020.

Accurate and timely reporting, as well as record keeping, is critical to stellar contract administration. A contractor’s affirmative action obligations in the hiring and retention of Veterans are subject to audit by the U.S. Department of Labor’s Office of Federal Contractor Compliance Programs (OFCCP).

A special note to the U.S. Department of Veterans Affairs (VA) Federal Supply Schedule Contract holders. VA requires submission of this report to the U.S. Department of Labor regardless of the dollar amount of sales under the FSS contract, and failure to submit can impact the processing of modifications, extension packages, and new and ensuing offers.

About the Webinar:

Just in time for the annual VEVRAA reporting, Centre’s 90-minute VETS-4212 Reporting webinar will introduce VEVRAA, FAR Clause 52.222-37, to participants and teach them how to successfully prepare and submit a VETS-4212 Report to the Veterans Employment Training Service at the U.S. Department of Labor.

What You’ll Learn:

  • The iterative requirements of FAR Clause 52.222-37
  • Contractors’ and subcontractor’s obligations under VEVRAA
  • The steps necessary to take to prepare for VETS-4212 Report preparation
  • How to prepare VETS-4212 Reports
  • When, where, and how to submit a VETS-4212 Report
  • How to request an extension for submission, if necessary
  • About the Office of Federal Contractor Compliance Programs Audit and enforcement actions

Who Should Attend:

This timely webinar is designed for contractor personnel responsible for administering Federal government contracts with values > $150,000*, containing FAR Clause 52.222-37, Employment Reports on Veterans, and for subcontracts where the contractor has flowed the clause down to suppliers and subcontractors.  The webinar is an excellent refresher for seasoned contract administrators and is ideal for new contractor personnel and for those who are being trained as back-ups or support personnel for contract administrators.

*Note: Earlier versions of FAR Clause 52.222-37 contain lower dollar thresholds for reporting, e.g., FAR 52.222-37 (JUL 2014) has a reporting threshold of $100,000. The version of the clause in your contract(s) will dictate the reporting threshold.


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