EEO-1 and VETS-100 Reports Are Due September 30
This is a reminder that September 30, 2010 is the deadline for EEO-1 and VETS-100 reports filings, and there are several rules and requirements regarding such reports.
Organizations that employ 100 or more employees or organizations that employees 50 or more employees and maintain federal contractors or subcontracts of $50,000 or more must timely file EEO-1 reports (which includes race/sex data and occupational data by job categories during a selected payroll period in the year). Such reports may be submitted electronically (http://www.eeoc.gov/employers/eeo1survey/index.cfm) or by data file that meets the requirements described at http://www.eeoc.gov/employers/eeo1survey/datafile.cfm or by paper requests (only in extreme cases where Internet access is not available to the employer). Payroll period dates must be for one payroll period from the third quarter (July through September) in the current reporting year. Beginning with the 2009 EEO-1 survey, completion of the “Employer Grid for All Type 6 Records” is no longer required. However, employers must enter employment data for all company employees to the Type 2 (Consolidated Report). More information is available at Joint Reporting Committee at 866.286.6440 or email@example.com. Consequences for not filing the required EEO-1 survey may include an order compelling filing or potential termination of the federal government contract and debarment from future federal contracts.
Federal contractors and subcontractors with contracts that total at least $25,000 per year and whose contract was entered into prior to December 1, 2003 must timely file VETS 100 form (which includes report of the number of veteran employees and the number of new hires), and those with contracts that total at least $100,000 per year must timely file VETS-100A form. Such reports may be submitted electronically at http://www.dol.gov/vets/programs/fcp/main.htm or the forms mailed or submitted on a properly formatted disk. For the “number of employees,” any pay period during the third quarter (July through September) of the reporting year may be selected. For “new hires,” use the 12-month period prior to the pay period used to report the number of employees. Employees with federal contracts entered into before or after December 1, 2003 that reach the designated dollar threshold are required to complete both forms. More information is available at 301.586.1580 or firstname.lastname@example.org. Failure to file required VETS 100 form may include forbidding federal contracting officers to award or modify federal contracts.
More Tips for Ensuring I-9 Compliance
As Immigration Customs and Enforcement (ICE) (http://www.ice.gov) and the Office of Special Counsel (OSC) continue to bear down on employers through I-9 investigations and fines, it is critical that employers review their I-9 procedures to ensure compliance. In prior Employment Law Updates, we have provided you with tips on achieving good I-9 compliance. We are back with more tips to help employers in this complex area of Form I-9 Employment Eligibility Verification (http://www.uscis.gov/files/form/i-9.pdf).
Please contact a member of Foley’s Labor & Employment team with questions or for further information about I-9 compliance and the government’s current enforcement initiatives.
Legal News is part of our ongoing commitment to providing legal insight to our clients and colleagues. If you have any questions about or would like to discuss these topics further, please contact your Foley attorney or any of the following individuals: