Washington Management Group

A Friendly Reminder – DOL Reports are Coming Due

Practical Advice on GSA Schedule Contracting
By: Carolyn Alston, General Counsel, Washington Management Group

August 2011

The submission date for two different reports to the Department of Labor (DOL) is coming soon. Covered contractors must submit the EEO-1 and the VETS-100/VETS 100A by September 30. DOL has, however, extended the date for submission of the VETS-100/VETS 100A Report.

What are these reports? I will explain here.

VETS-100/VETS 100A Reporting

Contractors use the VETS-100 or VETS-100A to report annually the number of protected veteran employees and new hires in their workforce. A federal contractor must file the reports under the following circumstances:

  • VETS-100A Report if it has a current contract or subcontract entered into on or after December 1, 2003, valued at $100,000 or more. A company also uses the form if it has a contract or subcontract that was modified on or after that date and the modification is valued at $100,000 or more.
  • VETS-100 Report if it has a current contract or subcontract entered into before December 1, 2003, valued at $25,000 or more.

DOL originally planned to accept electronic submissions of VETS 100/VETS-100A forms on August 1, 2011. However, the system has experienced technical problems. DOL anticipates resolving the problems soon and expects electronic filing to go online as of October 1, 2011. To address the delays in reporting caused by these technical problems, DOL has announced that it will not initiate enforcement actions against contractors who submit the VETS-100/VETS-100A from October 1, 2011 through November 30, 2011.

EEO-1 Reporting

Contractors use the EEO-1 Report, Standard Form 100, to report on the number of employees in their workforce by race, ethnicity, gender, and job categories. A federal contractor with 50 or more employees and a contract, subcontract, or purchase order valued at $50,000 or more must file the EEO-1 Report. DOL prefers that companies file the EEO-1 online here:


Please contact your WMG Consultant if you have questions regarding these reporting requirements.

Do you have a government contracting question? Please email it to me at CarolynsCorner@washmg.com.

About Carolyn:

Carolyn Alston is General Counsel of Washington Management Group. She provides legal counsel to WMG's federal acquisition consulting operation, focusing on Multiple Award Schedule contract award, compliance, and audit procedures.

Prior to joining WMG, Carolyn had a distinguished career with the U.S. General Services Administration. Her experience as a senior attorney in the GSA's Office of General Counsel led to her role as the lead in developing and writing GSA's Multiple Award Schedule policy. Her GSA career culminated in running the agency's successful GSA Schedule program as Assistant Commissioner for Acquisition at GSA.

Carolyn holds a BA from Cornell University and a JD from Georgetown Law Center. Carolyn is a member of the bar in Maryland and the District of Columbia.


WMG offers the information provided on this web site for informational purposes only.

WMG is a well recognized expert in GSA Schedule contracting, with more than 30 years of corporate experience. The information provided on this site is based on our substantial acquisition expertise, particularly with respect to commercial item contracting. Nothing on this site should be interpreted as legal advice.

As you recognize, most decisions regarding your GSA Schedule contract are highly dependent upon the facts of your particular circumstances. You should not rely on this site to make specific decisions about your contract. If you are considering taking specific actions on a matter affecting your GSA Schedule contract, we highly recommend that you contact WMG regarding a proposal for individual acquisition consulting services or that you seek advice from legal counsel with expertise in GSA Schedule contracting.


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