As previously reported, many federal contractors will be required to file their first annual VETS-100A report by September 30, 2009 based on a final rule issued earlier this year. In order to complete the new report, federal contractors covered by the new rule must start collecting the required data no later than August 31, 2008.

The VETS-100A, like the VETS-100, requires a federal contractor to have 12-months of data collected. The 12-month period must end on a date between July 1 and August 31, 2009. Likewise, this means that the contractor must begin collecting the data between July 1 and August 31, 2008. If you are a federal contractor, and if you will be required to fill out the new VETS-100A form, you should either already be collecting data or must start collecting it before August 31.

The categories of veterans reported on the new form are different from those reported on the VETS-100 form. The categories include only the following: disabled veterans, other protected veterans, armed forces service medal veterans, and recently separated veterans. In addition, some of the definitions have been changed even though the terms remain the same. Be sure to review the as well as the instructions and definitions carefully.

Only employers with federal contracts worth $100,000 or more entered into on or after December 1, 2003 will be required to file the VETS-100A report. Modifications made on or after December 1, 2003 of pre-December 2003 federal contracts create new contracts and are subject to the $100,000 threshold. Therefore, contractors would no longer be required to file the VETS-100 report for these modified contracts and would only be required to file the VETS-100A report if the modified contract meets the $100,000 threshold.