“Here are what federal contractors should note come Monday, September 21.
Self-Identification for Individuals with Disabilities Is No Longer Required
Federal contractors will no longer be required to invite applicants and employees to self-identify their disability status. Additionally, the Voluntary Self-Identification of Disability Form (CC-305) that has long been used and required by the OFCCP for contractors to distribute to their applicants and employees to self-identify, will be formally discontinued. The OFCCP’s rationale here was that employer-initiated disability inquiries conflict with the Americans with Disabilities Act (ADA) and that asking an applicant or employee to disclose disability information was contrary to the tenants of the ADA.
Takeaway: Federal contractors should remove Form CC-305 from their application packages and employee paperwork and should no longer require that applicants or employees self-identify their disability status.
OFCCP’s 7% Utilization Goal for Individuals with Disabilities is Eliminated
The OFCCP’s long-standing goal that individuals with disabilities comprise at least 7% of each job group within a federal contractor’s workforce is no longer required. As part of this rescission, the requirement to conduct an annual utilization analysis and develop action-oriented programs based on attainment of the goal, will also be eliminated. The OFCCP’s thought process seems to be that, since Form CC-305 was intended to collect data for the purpose of measuring progress towards the 7% utilization goal, by eliminating Form CC-305, the utilization analysis also becomes obsolete.
Takeaway: Federal contractors should no longer conduct a utilization analysis related to individuals with disabilities with the purpose of determining if they have hit the 7% utilization goal.”