On Tuesday, January 20, 2015, the OFCCP released two FAQs clarifying the self-ID requirements under the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA) in light of recent changes to 41 CFR 61-300 (VETS-4212, formerly VETS-100 and VETS-100A).
VEVRAA requires contractors to invite applicants, post-offer, to self-identify “whether the applicant believes he or she belongs to one or more of the specific categories of protected veteran for which the contractor is required to report pursuant to 41 CFR part 61-300.” In October, 41 CFR 61-300 was revised to require contractors to report protected veterans in the aggregate rather than by individual protected veteran category.
The first FAQ clarifies that, as a result of this change, contractors are no longer required to invite applicants to self-identify using the individual protected veteran categories in the post-offer stage. However, the second FAQ does indicate that contractors may continue to solicit information on the four categories of protected veteran as long as they provide the data to VETS in the aggregate on the VETS-4212 form.
By Dave Sharrer, M.S., Consultant, DCI Consulting Group
