Employment Reports on Veterans
Federal contractors must annually report workforce data on protected veterans using the VETS-4212 form by September 30 and flow down this requirement to qualifying subcontractors.
Overview
FAR 52.222-37 requires federal contractors (excluding state and local government agencies) to annually report workforce statistics related to protected veterans. The clause defines key veteran categories and mandates the use of the VETS-4212 report to disclose the number of protected veterans employed, new hires, and workforce size at each hiring location. Reports must be submitted by September 30 each year, covering a 12-month period ending between July 1 and August 31 (or December 31 with EEOC approval). Contractors must base their reporting on known data, which can be obtained through self-identification or other means, and are required to flow down this clause to applicable subcontracts at or above the FAR 22.1303(a) threshold. The regulation aims to ensure transparency and compliance with veteran employment reporting requirements under federal law.
Key Rules
- Annual Reporting Requirement
- Contractors must file the VETS-4212 report annually, detailing the number of protected veterans in their workforce and among new hires, as well as workforce size at each location.
- Reporting Deadline and Period
- Reports are due by September 30 each year and must cover a 12-month period ending between July 1 and August 31, unless EEOC approval allows a December 31 end date.
- Data Collection Methods
- Veteran status may be determined through self-identification, voluntary disclosure, or contractor knowledge, but this does not exempt contractors from anti-discrimination laws.
- Subcontractor Flowdown
- The clause must be included in subcontracts at or above the specified threshold unless exempted.
Responsibilities
- Contracting Officers: Ensure inclusion of this clause in applicable contracts and subcontracts.
- Contractors: Collect, maintain, and report required veteran employment data using VETS-4212; ensure timely submission; flow down requirements to qualifying subcontractors.
- Agencies: Oversee contractor compliance and reporting.
Practical Implications
- This clause exists to promote veteran employment transparency and compliance with federal law.
- Contractors must establish reliable data collection and reporting processes to avoid noncompliance.
- Common pitfalls include missing the reporting deadline, incomplete data, or failing to flow down the clause to subcontractors.