Federal Contractors Update: OFCCP New Policies and 2018 VETS-4212 Report Filing

Recently, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs announced three new directives, and the DOL’s Veterans’ Employment and Training Service opened the filing season for the VETS-4212 report. 

Directives issued by the OFCCP:
  1. Directive 2018-05, Analysis of Contractor Compensation Practices During a Compliance Evaluation: Outlines standard procedures for reviewing contractor compensation practices during a compliance evaluation and emphasize OFCCP's priority of eliminating pay discrimination through enforcement by OFCCP and compliance by contractors through proactive self-auditing.
  2. Directive 2018-06, Contractor Recognition Program: Recognizes contractors with high-quality and high-performing compliance programs and initiatives that are innovative, have achieved demonstrable results and that could be taught or incorporated into contractor peer mentoring programs. These programs should have a record of accomplishment related to nondiscrimination and providing applicants and employees with equal employment opportunity under the laws enforced by the OFCCP. 
  3. Directive 2018-07, Affirmative Action Program Verification Initiative: Implements a verification process to ensure that all covered federal contractors are meeting the most basic equal employment opportunity regulatory requirement, namely, the preparation of a written affirmative action program and annual updates to that program. OFCCP says this will help American workers by ensuring that all covered federal contractors have AAPs, which will result in enhanced equal employment opportunity, more contractor outreach to available workers and a more diverse workforce.
For further information, see the articles OFCCP Reins in Compensation Analysis by Rescinding Directive 307 and Issuing New Guidance and Something Old, Something New: Contractor Recognition and AAP Verification on the Horizon at OFCCP, prepared by ABC’s general counsel, Littler Mendelson P.C. 

2018 VETS-4212 Report Filing 

According to the DOL’s Veterans’ Employment and Training Service, the 2018 filing season for the VETS-4212 report started on Aug. 1, 2018, and ends on Sept. 30, 2018. 

As discussed in an article prepared by ABC’s general counsel, Littler Mendelson P.C., “The VETS-4212 report is an annual report that provides information regarding the number of protected veteran employees in each job category, as well as the number of protected veteran new hires for the preceding 12-month period by job category. Covered federal contractors and subcontractors must file the 2018 VETS-4212 report if they held a federal contract or subcontract valued at $150,000 or more at any point during calendar year 2017.”


2018 VETS-4212 Report
Frequent Asked Questions about the VETS-4212 Report 
Veterans’ Employment and Training Service website

This article is intended for informational purposes only and does not constitute legal advice or opinion.