The U.S. Department of Labor (DOL) has postponed for 60 days the September 30 filing deadline for submission of the VETS-100/VETS-100A forms required by the Vietnam Era Veterans’ Readjustment and Assistance Act of 1974 (VEVRAA). The DOL had planned on beginning to accept electronic submissions of the forms on August 1, 2011, but technical problems with the DOL website have prevented contractors from submitting online. The DOL advises that it is working on the problem, and expects the electronic filing system to be back online by October 1, 2011.

The DOL’s announcement is available here.

VEVRAA applies to contracts in excess of $100,000 entered into by any U.S. department or agency for the procurement of personal property and non-personal services, and any subcontract in excess of $100,000 entered into by a prime contractor carrying out any such contract. VEVRAA’s regulations require covered contractors to submit VETS-100 or VETS-100A annual reports to the Secretary of Labor detailing the number of protected veteran employees and new hires in their workforce.

To address the delays in reporting caused by these technical problems, the DOL announced that it will not initiate enforcement actions against contractors that submit the forms between October 1 and November 30, 2011, but that it may initiate enforcement actions against contractors that have not submitted by November 30, unless further updates regarding the filing deadline are provided in the meantime.

If you have questions about the delay or any aspect of VEVRAA, please contact David S. Fryman at 215.864.8105 or fryman@ballardspahr.com, Meredith C. Swartz at 215.864.8132 or swartzm@ballardspahr.com, or any member of Ballard Spahr’s Labor and Employment Group.


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