The VOW to Hire Heroes Act was signed today by President Obama.  (see Business Week article from today.)  As previously mentioned, this bill expands the eligible-veterans categories under the Work Opportunity Tax Credit (WOTC) program and extends the new categories through December 31, 2012. Unless the legislative language was modified prior to final passage, my understanding is that the new WOTC categories will become effective immediately.
Employers now have a job to do – update their WOTC screening tools to identify and document new hires who are members of the newly-targeted veteran groups. Any immediate changes, however, should be made with the understanding that the Department of Labor and IRS will also be updating WOTC regulations, documentation standards, and official WOTC forms. The last time significant changes were made to the WOTC program, it took months and multiple attempts for the government to finalize these changes.
In this regard, I should note that the bill includes language granting some degree of discretion to the Department of Labor when it comes to defining the documentation  requirements for the new categories.  On its face, the bill looks to a veteran’s unemployment insurance compensation history to document the required level of unemployment.  We hope, however, that other approaches will also be approved since not every unemployed veteran will necessarily have been eligible for unemployment insurance compensation.
Now that this bill has been signed by the President, I feel good about digging into the details of its legislative language. Stay tuned for further exploration and explanations.