For those unfamiliar with the topic, organizations that do business with the federal government and that have contracts over a certain dollar amount are required to complete either a VETS-100 or a VETS-100A form annually and report the total number of covered veterans it employs and the number it has hired in the last year.

The definition of a “covered veteran” varies slightly between the two forms, but generally includes:

• Disabled veterans
• Veterans of the Vietnam era
• Veterans who served on active duty in the U.S. military during a war or in a campaign or expedition for which a campaign badge is awarded
• Armed Forces service medal veterans
• Recently separated veterans (veterans within 36 months from discharge or release from active duty

The thought behind this requirement is that if businesses are going to take taxpayer dollars (in the form of government contracts), they have an obligation to follow affirmative action hiring practices and actively seek to employ, amongst other groups, military veterans.  A contractor found to be in violation could have its contracts canceled, terminated, or suspended in whole or in part, and the contractor may be debarred, i.e., declared ineligible for future government contracts.

The Office of Federal Contracts Compliance Programs (OFCCP), part of the Department of Labor, is responsible to audit government contractors and determine compliance for hiring veterans.  In an earlier blog I wrote how some HR and compliance professionals were being caught by surprise that the OFCCP was pressing for evidence that contractors were doing more than the bare minimum to find qualified veterans to hire.  The OFCCP has an incentive for businesses to do more – it’s called the Good Faith Initiative for Veterans Employment (G-FIVE), another topic which I’ve covered in this blog.  President Obama has requested a renewed focus on veteran employment and the employment of persons with disabilities, and this is driving the attention being paid to government contractors.

I attended an OFCCP event last year and sat in on several sessions that outlined compliance requirements for contractors.  Time and again, compliance professionals stated that they were doing what was required of them, but they just weren’t able to find qualified veterans to hire.

The bottom line is that it just isn’t a good excuse anymore for businesses to claim they’ve tried to find veterans to hire, when all they have done is the bare minimum the contracts law requires.   The minimum that any contract holder has to do is to file open job positions with the state employment agency.  The idea behind that requirement is that unemployed veterans will find the positions and apply for them and/or the Local Veteran Employment Representatives will see the positions and try to find qualified veterans to present to the employers.

But, as the G-FIVE program outlines, there are a lot of other types of outreach employers could be doing to find qualified veterans, and employers that take those additional actions are more likely to find veterans who are a good fit for the positions.

Military members are found in many places.  In my seminar “Military Applicant Sourcing Options” I cover more than a dozen methods to find military, including veteran-specific job boards, college campuses, professional associations, government agencies, non-profit groups and social media sites.

Many of the points made in The Washington Post article centered on whether contractors who met the criteria to file VET-100 forms were actually submitting the forms.  I believe that if you meet the criterion that requires your company to file the form – you need to file the form.  But more importantly, I believe that there is a risk of an increased scrutiny during OFCCP audits.  Companies who have been coasting by, doing the minimum, and giving excuses as to why they can’t find qualified veterans to hire could risk being flagged in the Central Contractor Repository and on the GSA schedules.

Over 165,000 service members will transition from the military this year.  More than a million men and women serve in the Guard and Reserve and too many will come back from a deployment to find their jobs have disappeared.  Almost 300,000 service members and veterans are enrolled in college and taking advantage of the Post 9-11 GI Bill benefit so they can find better jobs upon graduation.

I don’t buy the excuse that “qualified veterans are hard to find”.  You need to look harder in the right places.

Patricia Shiu (the Director of OFCCP) has made the enforcement of affirmative action efforts for covered veterans and persons with disabilities a top priority. Click here to read a transcript of a live Q&A session Ms. Shiu held on December 8, 2009 where she outlined the OFCCP’s priorities (and, yes, if you scroll down to 3:24 in the chat record that is yours truly asking a question about how the OFCCP plans to educate contractors on hiring veterans).  Given the unemployment rate of veterans (particularly in the 18-24 year old age group and especially women service members), the continued expansion of the active military force (most of whose members will return to civilian life at some point), the huge number of Guard and Reserve members who rotate back to civilian life and find themselves looking for new jobs, and the growing number of disabled veterans struggling to find work, it is not surprising that there is a renewed interest throughout many parts of the Federal government in improving veteran employment.

If you have read up to this point and are not convinced that this blog contains information that applies to your organization, you might be surprised to find out what kinds of employers may be required (depending on the size of the contract awarded) to comply with some level of OFCCP regulatory requirements:

• Any business with 50 or more employees and $50,000 or more in government contracts
• Construction contractors and subcontractors who hold a Federal or federally-assisted construction contract in excess of $10,000.
• Teaching hospitals doing research for a university that has a contract with the Federal government.
• Colleges/universities who have been awarded grants or contacts to do research for Federal Agencies.
• Businesses of all sizes that have been awarded American Recovery and Reinvestment Act of 2009 (ARRA) funds in the form of contracts or grants.

In particular with ARRA the bottom line is that if the government is giving your company tax-payer dollars to provide goods or services, it wants to know that you are making a sincere effort to employ and promote a diverse population.  That includes women, minorities, veterans and persons with disabilities.

If you are saying to yourself “Now, wait a minute – I only have to worry about my efforts in veteran outreach if my contract is over $100,000”, you would be technically correct (presuming that contract was awarded after December 1, 2003).  But if you recognized that the military demographic is over 41% non-white, almost 20% women, and includes a growing number of disabled veterans, you would quickly realize you could achieve many of your affirmative action goals just by making an effort to recruit service members in transition. Also, I would hope it is part of your long term business strategy to go after and win larger contracts/grants so you might as well begin the process now in preparation for winning “the big one”.

When it comes to outreach to veterans, many companies do the bare minimum the OFCCP requires, which is to list their job openings with their state workforce agency.  While that certainly meets the requirement, it hardly qualifies as an extensive outreach program.  Additional things an employer can do to improve outreach include:

• Provide on-the-job training opportunities to veterans
• Update your career page to attract veterans
• Reach out to veterans on campus in Reserve Officer Training Corps programs and Student Veterans of America chapters
• Host virtual open houses and communicate them to the military transition centers
• Contact the wounded warrior programs offered by each service
• Market your career web site and opportunities on social networking sites where veterans gather
• Post your jobs on military job boards or with military-focused recruiting firms and maintain records similar to what you must keep for outreach to minorities and women

(Click on any hyperlink above to read blog entries I’ve made on the topic or web seminars I offer that cover the topic or additional resources.)

To encourage employers to improve their hiring of veterans and veterans with disabilities the OFCCP came up with the Good Faith Initiative for Veterans Employment (G-FIVE).   Click here to read a blog I wrote 18 months ago on the G-FIVE.  Each December the OFCCP releases its list of organizations that have attained G-FIVE recognition.  Organizations that receive G-FIVE recognition are excluded from an OFCCP compliance evaluation for three (3) years following the date the recipient receives the rating. Companies can self-nominate to be considered for G-FIVE recognition.

If your organization has been through an OFCCP audit recently, or has applied/been considered for G-FIVE recognition, I’d like to hear about your experience and what you have discovered about outreach to veterans and veterans with disabilities.  Please be sure to comment below.

Are you aware that the OFCCP has created a new employer incentive called the Good-Faith Initiative for Veterans Employment (G-FIVE)? The OFCCP has identified some factors they will consider as evidence that a company is making a real effort to hire veterans. A few examples of the types of activities that show “good faith” are:

• Partnering with local Veterans Service Organizations to employ or advance covered veterans
• Recruitment efforts at educational institutions to reach students who are covered veterans
• Providing on-the-job training opportunities to covered veterans

Based on the outcome of a full compliance evaluation the OFCCP Regional Directors will make G-FIVE recommendations to the National Office of contractor and subcontractor establishments that have demonstrated outstanding achievements in the employment of covered veterans, based on a list of evaluation factors.

Contractor or subcontractor establishments that receive G-FIVE recognition will be excluded from an OFCCP compliance evaluation for three (3) years following the date the recipient receives the rating. Companies can self-nominate to be considered for G-FIVE recognition.

So, why am I telling you this? SHAMELESS PLUG: because I love the fact that many of the evaluation factors listed for G-FIVE recognition are the very same ideas I promote in my “Marketing to Attract the Military Applicant” and “Military Applicant Sourcing Options” web seminars. Check out www.TheValueOfaVeteran.com/webinars.html for complete list of seminar topics and session dates through December 2008.

My clients who are federal contractors are doubly excited – by participating in my seminars they’ve come away with a ton of great ideas, and just by implementing even a few of them they are well on their way to receiving G-FIVE recognition!

For more information on the Good-Faith Initiative for Veterans Employment (G-FIVE) go to the Department of Labor website: http://www.dol.gov/esa/ofccp/regs/compliance/faqs/dir282faqs.htm.

Posted by Lisa Rosser, Author of and Speaker/Workshop Leader on The Value Of a Veteran(TM): The Guide for Human Resource Professionals to Regarding, Recruiting, and Retaining Military Veterans

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