Revisiting VEVRAA – What Should Contractors Be Doing?
Untitled Document History of VEVRAA
President Gerald Ford passed Section 4212 of the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA) on December 4, 1974, which was originally created for veterans returning home from the Vietnam War. This was necessary because - generally speaking - society was biased against the war and the military men and women who served in Vietnam.

As a result, the community tended to view the newly returned veterans negatively and unemployment among the veterans ensued. VEVRAA prohibited companies that were awarded federal contracts from discriminating against veterans. In other words, it required affirmative action to safeguard equal opportunity for men and women in the military. This resulted in federal contractors being obligated to post all job vacancies with the state employment agencies.

At the time, the thresholds for contracts were $10,000 or more with the goal that federal contractors would take affirmative action to ensure equal employment opportunity without regard to veteran status.

Revised Regulations
The Office of Federal Contract Compliance Programs (OFCCP) recently revised its VEVRAA regulations because the original rules were implemented 40 years prior and unemployment rates for veterans returning from Iraq and Afghanistan is higher than the unemployment rates of the general public. The revised regulations went into effect on March 24, 2014.

The goal of the revisions is to continue reducing unemployment rates of protected veterans, which include:

Disabled Veteran
A veteran who served on active duty in the U.S. military and is entitled to disability compensation (or who but for the receipt of military retired pay would be entitled to disability compensation) under laws administered by the Secretary of Veterans Affairs, or was discharged or released from active duty because of a service-connected disability.

Other Protected Veteran
A veteran who served on active duty in the U.S. military during a war, or in a campaign or expedition for which a campaign badge was authorized under the laws administered by the Department of Defense.

Recently Separated Veteran
A veteran separated during the three-year period beginning on the date of the veteran's discharge or release from active duty in the U.S. military.

Armed Forces Service Medal Veteran
A veteran who, while serving on active duty in the U.S. military, participated in a U.S. military operation that received an Armed Forces service medal.

In addition, the revised regulations require federal contractors to establish an annual hiring benchmark for protected veterans. The benchmark is updated each year, and the current benchmark is 7%.

The regulations require federal contractors to document and update annually several quantitative comparisons regarding the number of veterans who apply for jobs and the number of veterans who are hired. The data is intended to assist contractors in measuring the effectiveness of their outreach and recruitment efforts keeping in mind the 7% benchmark. The data must be maintained for three years as it helps identify trends.

Below is an example of a log that I provide clients when recording the data for the revised VEVRAA regulations and the Rehabilitation Act of 1973, Section 503 regulations:

#of Openings # of Jobs Filled # Of Applicants # of Applicants Self ID IWD # of Applicants Self ID Vet Total # of Hires Total # of Vets Hired Total # of IWD Hired

Outreach Organizations
Since outreach is also an important part of VEVRAA, the following are non-profit organizations that I met personally or via phone and carefully scrutinized. From my experience, they are excellent tools for recruitment and resources. The four organizations train and work passionately to place “work-ready” veterans in all jobs throughout the country.

James Turner
Operations Support Specialist
Transforming Military Service into Civilian Success
Hire Heroes USA

Jim Minta
Operations Manager, Southeastern Region
Workforce Opportunity Services

Mark Baird

Adam Casas
Staffing and Recruiting
Veteran Jobs Opportunities

Additional Reporting
Each year, contractors and subcontractors are required to report annually on their affirmative action efforts in employing veterans. The Vets-100 report is rescinded and the Vets 100A report is renamed as the VETS-4212 report. The filing season for the VETS-4212 opened on August 1, 2015 and ended on September 30, 2015.

The purpose of this article was to give a high-level overview of what federal contractors and subcontractors are supposed to be doing since the revised VEVRAA regulations went into effect.

For more information regarding VEVRAA, read the FAQs posted on OFCCP’s website.

Perhaps the next amendment to VEVRAA will be to include all veterans.