Federal Contractors Must Update Disability Self-Identification Forms on February 1, 2017

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Federal contractors subject to Section 503 of the Rehabilitation Act of 1973 are required to invite applicants for employment and new hires to identify themselves as individuals with disabilities.  Covered contractors are also required to periodically survey current employees regarding their status as individuals with disabilities.  All such inquiries must be made using the form published by the Office of Federal Contract Compliance Programs (OFCCP), available at https://www.dol.gov/ofccp/regs/compliance/sec503/self_id_forms/selfidforms.htm.

Whether using a paper copy of this form or adopting it to an electronic applicant system, contractors must use the form in essentially the same format as published by OFCCP.  Changes to the text are not permitted and only minimal alterations to formatting are allowed.  Among other things, contractors must include information regarding the form’s approval by the Office of Management and Budget (OMB) including a reference to the document as “Form CC-305,” the OMB Control Number, and the date on which OMB approval expires.

Regarding this last requirement, astute contractors will have noticed that the OMB’s initial approval of the form expires on January 31, 2017.  Approval for the continued use of the form was granted on January 27, 2017.  All contractors required to use this form must now update their hard copy and electronic versions of the form to include the new expiration date of 1/31/2020.  The OMB Control Number remains the same.   

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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