In an effort to address confusion resulting from the new VETS-4212 Form, OFCCP recently posted two new FAQs addressing issues related to collecting and reporting disclosure data.

The first FAQ addresses whether contractors can continue to invite applicants voluntarily to self-identify as a protected veterans using individual categories of protected veterans in light of the fact the new VETS-4212 Form only asks for aggregated protected veteran data.  OFCCP explains that although not required, contractors may elect to have applicants identify the specific protected veteran category or categories to which they belong.

The second FAQ also addresses contractors’ obligation to request information from current employees.  The FAQ clarifies that, given the new VETS-4212 Form, contractors “are not required to invite self-identification by category in order to comply with VEVRAA’s post-offer invitation requirement.”  Contractors must only ask applicants offered a job to identify whether they are protected veterans under any of the categories set forth in VEVRAA.