OFCCP Requires Federal Contractors to Implement Revised Voluntary Self-Identification of Disability Form by July 25, 2023

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Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

On April 25, 2023, the Office of Management and Budget (OMB) approved the Office of Federal Contract Compliance Programs’ (OFCCP) revised Voluntary Self-Identification of Disability Form (CC-305). The current version of the form will expire on May 31, 2023. The new form will expire on April 30, 2026.

OFCCP revised the Voluntary Self-Identification of Disability Form to “update the preferred language for disabilities and to include additional examples of disabilities,” with the goal of increasing the response rate of applicants and employees on the form.

Specifically, the approved revisions include plain-language edits and formatting changes, such as changes to checkbox fields and a substitution of “physical or mental impairment or medical condition” for “condition.” The approved revisions also include the following new listed disabilities:

  • “Alcohol or other substance use disorder (not currently using drugs illegally)”
  • “Disfigurement, for example, disfigurement caused by burns, wounds, accidents, or congenital disorders”
  • “Mobility impairment, benefiting from the use of a wheelchair, scooter, walker, leg brace(s) and/or other supports”
  • “Neurodivergence, for example, attention-deficit/hyperactivity disorder (ADHD), autism spectrum disorder, dyslexia, dyspraxia, other learning disabilities”
  • “Partial or complete paralysis (any cause)”
  • “Pulmonary or respiratory conditions, for example, tuberculosis, asthma, emphysema”
  • “Short stature (dwarfism)”
  • “Traumatic brain injury”

Federal contractors and subcontractors must implement the new form by July 25, 2023.

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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