Editor’s note: We apologize for our mistake. We recently published an article on the VETS-4212 and EEO-1 reporting from our partners at Constangy, et al and inadvertently used an article from 2016. The correct article is below. We’re sorry for any confusion this mistake may have caused.
The following is a blog published byConstangy, Brooks, Smith & Prophete, LLP.in the Port St. Lucie, FL office of
In a letter dated July 24 from J.S. Schellenberger, Deputy Assistant Secretary of Labor, the DOL said that contractors could use the same data collection period that applies to the new EEO-1 requirements. In other words, contractors can collect their VETS-4212 “snapshot” data during the October 1-December 31 period.
However, the VETS-4212 reporting period of August 1-September 30 will remain unchanged for the time being. As noted in Mr. Schellenberger’s letter, the reporting deadline is required by applicable regulations and cannot be changed without notice-and-comment rulemaking. According to the letter, that is a possibility: “Such a rulemaking could be considered in a future update to the Department’s Regulatory Agenda.” (Emphasis added.)
But in the meantime, contractors who are required to file both EEO-1 reports and VETS-4212 reports must abide by the following deadlines:
EEO-1 and VETS-4212: Data can be collected during “snapshot” period between October 1 and December 31, 2017, and during the same fourth quarter in subsequent years.
EEO-1: Report, showing data from new “snapshot” period in 2017, must be filed no later than March 31, 2018. (No EEO-1 Report need be filed in 2017.) Subsequent EEO-1 reporting deadlines will be March 31 of each year.
VETS-4212: Report must be filed between August 1 and September 30, 2018, and during the corresponding period each year thereafter. “Snapshot” period can be the same as the one used for the EEO-1 Reports (that is, October 1-December 31, 2017, for the 2018 Report).
It is still possible that the Trump EEOC will act before March 31, 2018, to modify or eliminate the requirement to report compensation data. We will keep you posted.