by Patricia Schaeffer, Vice President-Regulatory Affairs

On May 19, 2008, the Department of Labor’s Veterans’ Employment and Training Service (VETS) published in the Federal Register a final rule and adopted a new VETS-100 form. The rule implements the requirement under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) that government contractors track and annually report the number of employees in their workforces who are veterans covered under the law.

The final rule implements amendments to the reporting requirements under VEVRAA that were made by the Jobs for Veterans Act (JVA) and becomes effective on June 18, 2008. It will implement the JVA changes to the reporting requirements under VEVRAA and will be codified in a new 41 CFR part 61-300. Employers with federal contracts worth $100,000 or more entered into or modified on or after December 1, 2003 will be required to file a new form – VETS-100A. Employers working on federal contracts of $25,000 or more that predate December 2003 must continue to file VETS-100. Federal contractors covered by the JVA are to collect and maintain the data prescribed by the new part 61-300 regulations beginning in the calendar year 2008, and report the data in the VETS-100A Report to be filed by September 30, 2009.

CLARIFICATION: The final rule states that the VETS-100A Report is to be completed by each federal contractor or subcontractor with a contract or subcontract entered into or modified on or after December 1, 2003 in the amount of $100,000 or more. Contractors should review the final rule for more details on what constitutes a modification of a contract.

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