VETS-4212

Question: when is it required for a contracting officer to verify a contractor's VETS-4212 submission?

Background: FAR Clause 52.222-35 Equal Opportunity for Veterans is required in all contracts over $150,000. FAR Clause 52-222-37 Employment Reports on Veterans is required in all contracts containing FAR Clause 52.222-35. This clause says that contractors have to report veteran employment numbers. FAR Provision 52.222-38 Compliance with Veterans’ Employment Reporting Requirements says that the offeror's submission is their attestation that they have filed (as required). FAR part 22.13 discusses when submissions are required, but I cannot find anything in the FAR/DFARS/PGI/NMCARs where it talks about when it is required for the contracting officer to VERIFY this submission. The ONLY thing that i can find is FAR Part 22.1302(b) that says a "contracting officers must not obligate or expend funds appropriated for the agency...with a contractor that has not submitted the required annual VETS-4212" which (to me) would mean verifying the submission. However, 22.1302(b) also says this is not required for "contracts for commercial products or commercial services, or contracts that do not exceed the simplified acquisition threshold".

(MY) Conclusion: Verifying the contractors/subcontractors VETS report is NOT required for any base contract award or modification that is commercial or under SAT.