M A L Y   C O N S U L T I N G   L L C
December 15, 2007

Compliance Alert

New Rules and Reports for Veterans

Recent and pending regulatory changes issued pursuant to the Jobs for Veterans Act (JVA) alter the following important areas of veterans requirements:
  1) Categories of Covered Veterans
  2) Job Posting Requirements
  3) Veterans Reports Submitted to the Department of Labor (VETS-100)

These changes apply only to those companies with Government Contracts of $100,000 or more entered into on or after December 1, 2003. Companies with Government Contracts entered into before December 1, 2003 will still be covered by the old rules. Companies with Government Contracts from before and after December 1, 2003 will have to comply with both sets of rules.

1) Categories of Covered Veterans: Rule changes effective September 7, 2007 have changed the categories of veterans covered by affirmative action and reporting requirements. In summary, the new regulations:
    -Eliminate Vietnam Era Veteran as a separate category,
    -Create a new Armed Forces Service Medal Veteran category,
    -Expand coverage for disabled veterans, and
    -Expand coverage under the Recently Separated Veteran category.
For our clients, we have developed a new veteran self-ID sample that can be found on our website at www.malyconsulting.com/ClientsOnly.

2) Job Posting Requirements: Under the new JVA implementing regulations (41 CFR 60-300), with limited exceptions, all employment openings must be posted on an "employment service delivery system" defined as a service delivery system at which or through which labor exchange services, including employment, training, and placement services, are offered in accordance with the Wagner-Peyser Act. A list of state job banks that serve as employment service delivery systems is available online at www.jobbankinfo.org.

3) Vererans Reports Submitted to the DOL (VETS-100): Pending Veterans' Employment & Training Service (VETS) regulations will alter the VETS-100 report (called the VETS-100A report under the new version) to include the new categories of covered veterans. Information about the report and upcoming changes is available online at vets.dol.gov/vets100/.

Additional information about the regulation changes, including Frequently Asked Questions, is available on the OFCCP website at www.dol.gov/esa/ofccp/. If you have any questions about what your organization should do, please feel free to contact us.

Edward Correro - Editor
(415) 454-4921 (California Office)
info@malyconsulting.com

(301) 253-3183 (Maryland Office)
www.malyconsulting.com
990 A Street, Suite 402 • San Rafael, CA 94901 • (415)454-4921 • Fax (415)454-4914
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