VEVRAA Mandatory Listing Requirements

Arming Federal Contractors with Knowledge to Fully Comply with VEVRAA Mandatory Listing Requirements

The Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA) requires covered federal government contractors and subcontractors to take affirmative action to employ and advance in employment specified categories of protected veterans. These regulations also contain mandatory job listing requirements that federal contractors must abide by.

VEVRAA

§60-300.5

Equal opportunity clause

EXCERPT Listing employment openings with the state workforce agency job bank or with the local employment service delivery system where the opening occurs will satisfy the requirement to list jobs with the appropriate employment service delivery system (emphasis added). In order to satisfy the listing requirement described herein, contractors must provide information about the job vacancy in any manner and format permitted by the appropriate employment service delivery system…

Source: 41 CFR §60-300.5(a)(2)

What Qualifies as an ESDS?

On March 24, 2014 the Final Rule appended language to define “employment service delivery system” (ESDS) in accordance with the Wagner-Peyser Act of 1933, as amended by the Workforce Investment Act of 1998. The following delivery points allow federal contractors to meet the mandatory listing requirements:

  • State Workforce Agency Job Banks
  • Wagner-Peyser funded State Workforce Agencies or CareerOneStop Centers
  • Employment Service (ES) staff
  • Disabled Veterans Outreach Programs (DVOPs)
  • Local Veterans Employment Representatives (LVERs)

What is the Difference Between Listing and Posting?

Another component of VEVRAA’s mandatory listing requirements is priority protected veteran referrals. This part of the regulation states that federal contractors must list their jobs at the local ESDS to provide for priority veteran referrals. This means that Protected Veterans covered under the VEVRAA regulations will be given 24-hour priority access to job listings, prior to being available to non-veteran job seekers. Federal contractors who manually post jobs into the state job banks or local ESDS’s—without listing jobs via fax, email, certified mail or with their local veteran’s employment representative (LVER)—could be cited for not meeting the listing requirements.

“If you post, but don’t list, you will be cited.”

Melissa Speer, Regional Director, OFCCP SWARM Region
(stated at ILG National Conference on 8/7/14)

Job listingJob listing refers to the act of the federal contractors transmitting their job openings to either the local ESDSs or state job bank. This can be done in a variety of ways—i.e. mail, email, direct entry into state job banks, automatic indexing, direct feeds–as long as the appropriate ESDS says it is a valid format and enables the ESDS system to conduct priority referrals.
Job listingJob posting refers to the act of the State or local ESDS (not federal contractors) having received the job listings supplied by federal contractors via any of the methods listed to the left, and “posting” those job listings on the state job bank. Federal contractors are not required to post to state job banks, as long as they can prove “job listing” as described.

DirectEmployers’ History with VEVRAA Regulations

DirectEmployers Association has a rich history in helping federal contractors comply with the OFCCP’s mandatory job listing requirements. As a matter of fact, we’ve been in the space since 2001. View our historical timeline.

October 2001
Association formed; DirectEmployers delivers Members’ jobs to America’s Job Bank (AJB)
March 2007
DirectEmployers announces partnership with the National Association of State Workforce Agencies (NASWA)
June 2007
AJB discontinued by the federal government
July 2007
VetCentral made available for job delivery to keep Members in compliance with VEVRAA mandatory job listing requirements
April 2010
Just three years into the partnership, DirectEmployers and NASWA sign five-year partnership extension
June 2014
DirectEmployers and NASWA sign a 10-year partnership extension (view press release)

Are you a federal contractor looking for comprehensive job distribution?

Developed as a job distribution tool with long-time partner SourceCast, VetCentral delivers Members’ jobs via fax, email or certified mail to the appropriate Wagner-Peyser center to ensure they are listed according to the VEVRAA mandatory listing requirements. Learn more about our OFCCP Reporting.