REMINDER REGARDING VETS-4212 AND EEO-1 FILINGS

August 18, 2017 Advisory

VETS-4212 REPORT

The filing period for the VETS-4212 is currently open. Federal contractors and subcontractors with a contract valued at $150,000 or more are required to submit this annual report no later than September 30, 2017.

Covered contractors must report the number of employees and new hires who are protected veterans. The definition of protected veterans is: (1) Disabled veterans; (2) Active duty wartime or campaign badge veterans; (3) Armed Forces service medal veterans (veterans who, while serving on active duty in the Armed Forces, participated in a United States military operation for which an Armed Forces service medal was awarded pursuant to Executive Order 12985); and (4) Recently separated veterans (within three years from discharge or release from active duty).

The number reported must be from a pay period with an ending date that is between July 1 and August 31. For specific information regarding filing procedures and the VETS-4212 report, please click here: www.dol.gov/vets/vets4212.htm

EEO-1 REPORT

This is a reminder that there will be no actual EEO-1 filing this fall. In the past this annual report has been due by September 30. Because of the new compensation component required this year, the 2017 EEO-1 report will be due by March 31, 2018.

Will your employer be required to file the revised EEO-1 report? The following is from the EEOC's Revised EEO-1 and Summary Pay Data Questions and Answers:

"Starting with the 2017 report, which will be due on March 31, 2018, private employers including federal contractors and subcontractors with 100 or more employees will submit summary pay data.

Federal contractors and subcontractors with 50-99 employees will not submit summary pay data but will continue to report demographic data (sex and race or ethnicity) as they did before.

Federal contractors and subcontractors with 49 or fewer employees, and companies without federal contracts with 99 or fewer employees, will not be required to complete the EEO-1 report."

For specific information regarding filing procedures and the EEO-1 form, click here: https://www1.eeoc.gov//employers/eeo1survey/2017survey-qanda.cfm

Please note that the workforce snapshot period has changed for the 2017 EEO-1 report. Previously, employers were able to select a pay period in the third quarter of the calendar year, or between July 1 and September 30. This allowed employers to be able to select the same pay period for both the VETS-4212 and the EEO-1 reports. For the 2017 EEO-1 report, employers must use a pay period in the fourth quarter between October 1 and December 31.

Beginning in 2018, according to the DOL, contractors may use the same data collection period (i.e., January 1, 2017 – December 31, 2017) for the snapshot period for both the VETS-4212 and EEO-1 reports. However, the deadline for filing each of the forms remains the same.

As of now, the March 31, 2018 deadline for the EEO-1 is still in effect. The issue of the new EEO-1 reporting requirements has been sent to the Office of Information and Regulatory Affairs with the OMB (Office of Management and Budget) for review and many are still hoping that the current administration will either get rid of or delay implementing the new pay component. However, until this occurs, employers need to ensure that procedures are in place to gather the necessary information pertaining to salary and hours worked in order to meet the March 31st deadline.

For additional information, please feel free to contact either Robin Martocci at 860-297-3710 or John Zandy at 203-498-4330.