The Office of Federal Contract Compliance Programs (OFCCP) has
issued new guidance regarding the post-offer invitation to
self-identify protected veteran status. In its FAQs, the OFCCP now explains that
“since the new VETS-4212 report no longer requires contractors to
provide this information by the individual protected veteran
categories, contractors are not required to invite
self-identification by category in order to comply with VEVRAA’s
post-offer invitation requirement. Rather, contractors need only
invite those offered a job to indicate whether they are protected
veterans under any of the VEVRAA categories.”
Although it is no longer required, contractors may choose to
continue soliciting the individual protected veteran categories
at the post-offer stage if desired. If your systems have already
changed in response to the VEVRAA regulations released last year,
there is no requirement to make an additional change.
As background, when new VEVRAA regulations were announced last
year, the OFCCP provided a sample invitation to self-identify as
an appendix to the regulations. The sample form invited new
employees to voluntarily self-identify as belonging to each of
the individual categories of protected veteran. These categories
aligned with the protected veteran categories that Federal
contractors were required to report on the annual VETS-100A form
issued by the Veterans Employment and Training Service
(VETS).
Subsequent to that appendix being published, VETS has replaced
the VETS-100A form with the VETS-4212. The VETS-4212 collects
data by aggregated protected veteran status rather than
individual category.
HR Works, Inc. has released a revised sample Invitation to Self-Identify. If you are an
affirmative action client with HR Works and have questions or
need further assistance, please reach out to your Project Manager
via email or at (877) 219-9062.
