With August comes federal contractors' obligation to file the annual VETS-4212 report—which collects information on contractors' employees who are protected veterans—based on a snapshot of their workforce taken between July 1 and August 31.

In March 2018, however, employers for the first time also must disclose summary compensation data by race, gender, and ethnicity (unless before that time the Trump administration takes steps to eliminate this new requirement) as part of their annual EEO-1 report. In response to a letter from the Institute for Workforce Equality noting the burden associated with pulling data at two different times during the year, the Department of Labor recently clarified that, starting in 2018, federal contractors may align their VETS-4212 and EEO-1 data-collection periods by using a December 31 snapshot for both reports.

Federal contractors still must file their VETS-4212 report this year between August 1 and September 30 using data pulled between July 1, 2017, and August 31, 2017. But for 2018 and beyond, federal contractors have the option of pulling the workforce data only once—as of December 31—for both their EEO-1 report (filed by March 31), and VETS-4212 report (filed between August 1 and September 30).

Ballard Spahr's Labor and Employment Group regularly assists federal contractors with their affirmative action reporting obligations and assists all employers with their EEO-1 reporting and data-collection and compensation analysis.


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