The Center for Workplace Compliance, our affiliated nonprofit membership association, has filed comments with the Office of Federal Contract Compliance Programs urging it to consider alternatives to its proposed elimination of Form CC-305. Federal contractors use the Voluntary Self-Identification of Disability Form to solicit the disability status of their job applicants and employees.
OFCCP recently proposed eliminating the requirement for contractors to “invite applicants and employees to self-identify their disability status,” along with the quantitative analytics that stem from tracking and tabulating these invitations.
CWC’s comments urge OFCCP to retain Form CC-305 as a permissible — but not mandatory — method of soliciting disability status to support federal contractors’ Section 503 compliance programs. Our comments note that CWC members collectively have invested millions of dollars in time and resources implementing and maintaining Form CC-305. We assert that Form CC-305 should remain a viable option for those contractors that intend to continue soliciting their employees’ disability status.
Federal contractors should continue to comply with Section 503 recordkeeping and reporting requirements, including the use of Form CC-305. We see no need for contractors to reschedule any upcoming workplace disability surveys unless and until OFCCP eliminates this requirement.
CWC members can read more here.