I recently received an inquiry from someone who was newly charged to develop the military recruiting program for his company. He wanted to know how he could determine the number of veterans currently employed at his firm. He had participated in a company diversity meeting where there was much data on the number of female employees employed at the company and that information was used to discuss strategies for increasing the number of women hired and positioned as part of a diversified succession plan.
Because there seemed to be so much data on the number of women employees, the writer assumed the company would have similar data for the number of veterans employed by the company. He was frustrated to learn that, after much delay and hemming and hawing, the diversity lead stated that the information was protected as it is considered personal information, and therefore it could not be released to him. Recall that, at this stage, he was just trying to establish a baseline number, not actually collect the names of veterans employed by the company.
My response was that I suspect the reluctance to provide the information had more to do with the fact that his company had not been tracking veteran status well prior to this point. Plus, the diversity lead may not realize that the company keeps some records of military hires for purposes of compliance with the Office of Federal Contracts Compliance Programs (OFCCP).
My advice on steps to take to establish a baseline number of military veteran employees is:
- Any company that falls under OFCCP has to submit a VETS-100 or 100A form every year detailing the number of “qualified covered” veterans it currently employs and has hired in the last year. Note that not every former military member hired meets the definition of “qualified covered veteran”, so there are likely more vets in the employee base than would be reflected on the VETS-100 or 100A form. Veterans that meet “qualified covered” status are:
- Served during a war or campaign for which a campaign badge was awarded
- Recipients of the Armed Forces Service Medal (AFSM)
- Recently (within 36 months) separated from active duty
This is not a perfect method, as a hired veteran could qualify under more than one category and be counted in all the categories for which he/she qualifies (example: if a veteran is recently separated, has an AFSM AND is disabled, he/she could be counted 3 times.
2. If your company tracks (directly or through a 3rd party vendor) the number of Work Opportunity Tax Credits (WOTC) it has earned for hiring specific categories of veterans (those with disabilities, those unemployed for 6 weeks/6 months or those on food stamps), you may be able to get a report on the number of vets hired that meet those criteria. There may be some overlap with item #1 as one of the WOTC categories is veterans with disabilities.
3. If your company offers military leave or a pay differential for National Guard or Reserve members who have been called up to active duty, your HR department may be able to report the number of people who have used that military leave or pay differential in the last 10 years (or at least in the the last year). This will get you some data on Guard/Reserve employees, but presume the number is larger as not all will have been called to active duty since 9/11.
4. Lastly, if your company has a veteran employee resource group (ERG), the leader of that group may have some “home grown” data on the members of the group.
So, yes, it is a pain in the rump to establish the baseline, but it can be done. Going forward, HR should ask applicants to self-identify as military members at the point of application, at the job offer and periodically after they have been hired. Many HR information systems have a feature where an employee can self-identify as a veteran in their employee profile so it is easier to generate reports in the future. However, many of those HR systems only provide the categories that are required by the VETS-100/100A form, which does not cover all people who have served or continue to serve in the military (please see my last blog “What is the Definition of a ‘Veteran’?”)
You could ask your HRIS provider to add three categories, which will allow you much more insight into the number of military members (and spouses) you truly have:
- “Separated / Retired Military – does not meet any of above definitions”
- “Currently Serving National Guard/Reserve – does not meet any of above definitions”
- “Military spouse”
What other techniques have you used to baseline the number of military members in your company? Please share your ideas in the comments below.