Reminder about VETS-100/VETS-100A extended reporting deadline

The VETS-100 report is required for most entities with federal contracts that were entered into before December 1, 2003, and that have a value of $25,000 or more. The VETS-100A report is required for contracts entered into on or after December 1, 2003, in the amount of $100,000 or more. A contract modified on or after December 1, 2003, that was entered into before December 1, 2003, constitutes a new contract and therefore requires the contractor to file a VETS-100A report if the $100,000 or more threshold is met. Contractors that have contracts that fall into both categories are required to file both forms. Normally, the VETS-100/VETS-100A reporting cycle begins on August 1 and ends September 30.  In 2011, 'technical difficulties' prevented VETS from beginning to accept reports 'as usual' on August 1, 2011.  At that time, VETS announced that it expected it would have the issues resolved in time for the electronic filing system to be up by October 1 with a November 30 reporting deadline. However, due to continuing technical problems, the electronic filing system did not go live until November 1.  While the reporting deadline would normally have expired on December 30, 2011, the period has been extended to January 15, 2012.  View more information.  Please note the caution that all covered contractors, regardless of whether they have done so in the past, must register for the 2011 cycle because every company is going to be given a 'new number.'  Please also note that the web site suggests that there are some ongoing problems, so the report may be filed electronically, or by e-mail, or by regular mail, but it must be received by the government by January 15.  Finally, take note of this caution on the web site:  'Please be aware that there is a delay in the delivery of the confirmation email after registration.  Please check your email at a later time.'  So this is something that should not be moved to some back burner.

The material in this blog is not intended, nor should it be construed or relied upon, as legal advice. Please consult with an attorney if specific legal information is needed.