The Veterans' Employment and Training Service (VETS) of the United States Department of Labor (DOL) has issued a final rule regarding federal contractors' obligations to file annual reports with the DOL on their employment of covered military veterans. Specifically, the VETS-100A form is intended to implement the requirement under the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA), as amended by the Jobs for Veterans Act (JVA), that government contractors track and report the number of employees who are veterans covered by the JVA. The JVA raised the dollar amount of government contracts that trigger reporting obligations and changed the categories of veterans that contractors are required to track and report, thereby changing the reporting requirements for federal contractors who employ military veterans covered by the final rule.

Pursuant to the final rule, which was published in this Monday's Federal Register and will take effect 30 days later, employers who, on or after December 1, 2003, entered into or modified government contracts of $100,000 or more will be required to file a new form, the VETS-100A, with VETS. Notably, employers with government contracts that pre-date December 1, 2003, and are worth $25,000 or more must continue to file the VETS-100 form. Although some federal contractors may need to file both forms, VETS expects that the majority of federal contractors will be required to file one form. Federal contractors covered by the JVA must file the new VETS-100A form by September 30, 2009.

If you want to know more about the final rule and how it may affect your organization, call Ballard Spahr. Our Labor, Employment and Immigration lawyers can assist in making determinations as to whether your organization is covered by the final rule and how to comply with the reporting requirements. For more information, contact Frank Chernak at 215.864.8234 or


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