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.”