Federal Contractors Must Update Voluntary Self-Identification of Disability Form

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On May 5, 2020, the Office of Management and Budget (OMB) approved the Office of Federal Contract Compliance Programs' (OFCCP) revised voluntary self-identification of disability formFederal contractors and subcontractors have until August 4, 2020, to adopt the new form for applicants and employees. 

Pursuant to Section 503 of the Rehabilitation Act, federal contractors and subcontractors with at least 50 employees and contracts of $50,000 or more are required to invite applicants and employees to self-identify as people with disabilities. These same contractors are expected to set an annual 7% utilization goal for individuals with disabilities across all job groups.

In announcing the new form, OFCCP stated that it believes the revised form is more "streamlined" and will "increase the response rate" of individuals voluntarily disclosing their disability status. The form is now one page (instead of two), lists different examples of disabilities, and removes the reasonable accommodation notice.

Federal contractors should promptly evaluate the steps they must take to implement the new form into application and onboarding processes so that this process is complete by August 4.

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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