OFCCP Requires New Self-ID Form

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The Office of Federal Contract Compliance Programs (OFCCP) has issued a new Individuals with Disabilities voluntary self-identification form for use by all federal contractors and subcontractors who are obligated to maintain affirmative action plans.  This new form must be used starting 8/4/2020 and is available here.  Although completion of the form by applicants and employees is voluntary, it is required for covered federal contractors to provide this form to all applicants during the application process and to all employees on an annual basis.

The prior version of this OFCCP form effectively expires on 8/4/2020.  Going forward, please ensure that your organization uses the new version of the form for its annual distribution to employees.

The most significant change in this new version of the form is the inclusion of additional examples of disabilities.  It also includes a section for employers to use for recordkeeping purposes to facilitate data gathering and evaluation of the organization’s employment and utilization of Individuals with Disabilities, which is a required component of the annual Affirmative Action Plan.

Importantly, the instructions for this form specifically note that this section is the only section that an employer can modify.  Management and human resources employees should not otherwise annotate or modify the form, neither prior to distribution nor upon receipt of a completed form from an employee.  Customizations to the form are not allowed; please use the new version of the form in its current state.

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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