NT Lakis lawyers have submitted written comments to the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) in response to the agency’s announcement that it will seek formal approval to extend the various information collections associated with its revised Section 503 disability and Section 4212 veterans regulations, including the continued use of OFCCP’s prescribed disability self-identification Form CC-305.

Our comments caution OFCCP against mandating changes to Form CC-305 that could result in additional, expensive changes to contractors’ online application systems.  At the same time, we strongly encourage the agency to consider giving contractors more flexibility in complying with the invitation to self-identify requirements.

Our comments also request specific clarification that contractors be permitted to define the new “data collection analysis” items (commonly referred to as the “data metrics”) consistent with similar terms and data points already collected and maintained under Executive Order (E.O.) 11246, or otherwise in a way that makes sense for the contractor.

Members of the Equal Employment Advisory Council (EEAC) can read more here.