Do I file a VETS-100 or a VETS-100A report in 2009?


Issue:

Between August 1 and September 30, federal contractors and subcontractors with contracts of a certain dollar amount must report annually on the number of qualified covered veterans in their workforces and those hired during the reporting period. In 2009, for the first time, contractors are required to submit one of two reports and, in some cases, an employer will have to submit two reports. What is the difference between these reports and which report must a contractor file?

Answer:    

You must submit the VETS-100A Report in 2009 if you have:

  1. A current government contract or subcontract in the amount of $100,000 or more that was entered into on or after December 1, 2003; or
  2. A current government contract or subcontract that was modified on or after December 1, 2003, and the contract or subcontract as modified is in the amount of $100,000 or more.

You must submit the VETS-100 Report if you have a current government contract or subcontract in the amount of $25,000 or more that was entered into before December 1, 2003, except that you must submit the VETS-100A Report, not the VETS-100 Report, if such a contract or subcontract was modified on or after December 1, 2003, and the contract or subcontract as modified is in the amount of $100,000 or more.

For example, if you have a current government contract that was awarded on September 1, 2003, and the original amount of the contract was $50,000, but the contract was modified on February 1, 2004 and increased to $300,000, you must file the VETS-100A Report in 2009.

If you have a current government contract or subcontract in the amount of $25,000 or more that was entered into before December 1, 2003 (and not modified on or after that date) and a current government contract or subcontract in the amount of $100,000 or more that was entered into or modified on after December 1, 2003, you must submit both the VETS-100A and the VETS-100 Reports.

How do the reports differ? The most obvious difference is the categories of veterans included on each report. The VETS-100 Report calls for federal contractors and subcontractors to report the number of employees and new hires during the reporting period who are:

  1. Special disabled veterans;
  2. Veterans of the Vietnam era;
  3. Other protected veterans (veterans who served on active duty in the U.S. military during a war or in a campaign or expedition for which a campaign badge is awarded); and
  4. Recently separated veterans (veterans within 12 months from discharge or release from active duty).

The VETS-100A Report, on the other hand, calls for federal contractors and subcontractors to report the number of employees and new hires during the reporting period who are:

  1. Disabled veterans;
  2. Other protected veterans (veterans who served on active duty in the U.S. military during a war or in a campaign or expedition for which a campaign badge is awarded);
  3. Armed Forces service medal veterans (veterans who, while serving on active duty in the Armed Forces, participated in a United States military operation for which an Armed Forces service medal was awarded pursuant to Executive Order 12985); and
  4. Recently separated veterans (veterans within 36 months from discharge or release from active duty).

The other significant difference between the forms is in the job categories. The job categories on the forms are consistent with the job categories used on the EEO-1 Report. EEOC revised the EEO-1 Report in 2005 by, among other things, dividing the Officials and Managers category into two subgroups—Executives/Senior Level Officials and Managers and First/Mid Level Officials and Managers. The VETS-100A Report adopts the job categories used on the revised EEO-1 Report, while the VETS-100 Report has a single Officials and Managers job category.

Source: US Department of Labor, Veterans’ Employment and Training Service, http://www.dol.gov/vets/contractor/main.htm#8.

[ Return to top of document ]