Happy HR New Year!
If you are a Human Resources Professional for a company with 100 employees or 50 employees and $50,000 in federal contracts, you are probably in the midst of EEO-1 filing requirements. You also probably know that September 30th is a big day for Human Resources professionals as it marks the due date for when your EEO-1 report is due to the Office of Federal Contract Compliance Programs (OFCCP). This is (or should be) a regular part of your recurring calendar year, along with open enrollment, annual compliance training, OSHA training and reporting requirements, and of course the Company holiday party.
I like to call September 30th “HR New Year.” For those of us already in the swing of reporting requirements with an HRIS to run our reports for us, and an Affirmative Action Plan in full effect, HR New Year is simply another date on the calendar. We spend a little bit of time running reports and filling out the online applications to be submitted and move on to thinking about where to host that holiday party.
Unfortunately, for others of us, especially those of us who just met the reporting requirements, are new to the field of Human Resources, or who recently realized our Company is out of compliance, HR New Year brings an overwhelming feeling of uncertainty and confusion. If you are among those of us who are paralyzed by the mere thought of the OFCCP requesting an audit of information we haven’t even begun to collect, this article is for you… Let’s unpack some of the questions you may have:
Am I even required to celebrate HR New Year? (Complete and submit the EEO-1 report) If your company employs 100 or more people, or if it employs 50 people and holds $50,000 in government contracts (we call this the 50/50 rule), you should be celebrating HR New Year.
We have never collected the type of employee data required for the EEO-1 report before. How do I go about collecting that information? First things first: do NOT guess an employee’s ethnicity. Employees must be given the opportunity to self-identify. If an employee chooses not to self-identify, you may then use an employment record or visual observation. To invite employees to self-identify, utilize a paper or online form. From this point on, invite all applicants as well as new hires to self-identify.
How do I get set up to file online for the first time? Check out http://www.eeoc.gov/eeo1survey to get a username and password. Once you register, you will be provided with your username and password to file online. Save this information, as you will need to use it annually.
I think I have to file the VETS-100 or VETS-100A report as well. What do I need to know about that? September 30th also marks the due date for all VETS-100 and VETS100A reporting requirements. Employers who hold a federal contract or subcontract equal to or greater than $25,000, that was entered into prior to December 1st, 2003 are required to complete the VETS-100 report. Employers who hold a federal contract or subcontract equal to or greater than $100,000 that was entered into after December 1st, 2003 are required to complete the VETS-100A report. Note that you only have to complete one report, so make sure you understand which report you are required to complete.
How do I collect Veteran information? Employers are required to invite applicants and new hires to self-identify at two points in time: the first when an individual applies for a job, and the second when a new hire completes hiring paperwork. The first point of self-identification invites applicants to identify IF they fall into a Veteran protected status, and the second invites employees to identify WHICH specific category of protected status they fall into. This information can be collected via a form. It is imperative that employers invite applicants and employees to self-identify at both points, and that the correct questions are asked at each point.
I have never been required to complete a VETS-100 or 100A report before. How do I get started? First, you will need your Company’s DUNS and NAICS codes. To obtain those codes, visit this website: http://fedgov.dnb.com/webform and follow the step-by-step instructions for obtaining your codes. You will be asked to: 1) Look up your company 2) Verify your personal ID 3) Authenticate your personal ID and 4) Set up your security settings. Then, visit http://www.dol.gov/vets/vets-100.html#content to obtain your applicable blank report form, and submit your report online to: https://vets100.dol.gov/vets100 or email it to: VETS100-customersupport@dol.gov.
These frequently asked questions are just the tip of the iceberg when it comes to HR New Year reporting requirements. For more information or assistance in filing these reports, reach out to the experts at Skywalk Group.